# ! h!2
John R. Kasich

, Gov ern or
Mary Taylor, Lt

. Governor

Craig W. Butler

, Dire cto r

P r otect i on Agency



## A

P

R 2 I 2016

Robert A. Kaplan Acting Regional Administrator

Attn .: R-19J

U.S

. EPA

, Region 5

77West Jackson Blvd

. Chicago, Illinois 60604-3507

Re : Request for Approval of the Redesignation Request and Maintenance Plan for the Ohio

Portion of the**Cincinnati ~**  Area for the 2008 Eight-Hour Ozone Standard

Dear Acting

# Ad**or ,!;.-** 

1 am writing to formally request a redesignation to attainment of the Ohio portion of the Cincinnati, OH-IN-KY area (Butler, Clermont

, Clinton

, Hamilton and Warren Counties in Ohio ; Dearborn Township in Indiana (partial) ; and Boone

, Campbell

, and Kenton Count i es (part i al)

in Kentucky) with respect to the 2008 eight-hour ozone standard. The enclosed submittal

combines the redesignation request and the required maintenance plan for this area

.

Monitoring of existing air quality indicates that the 2008 National Ambient Air Quality

Standard (NAAQS) for ozone has been attained throughout this area based on certified

2012

- 2014 air quality data and preliminary 2013

- 2015 air qua l ity data. Em i ssions projections

indicate that current controls, existing State rules

, existing federal rules, and Ohio ' s PSD

program will be more than sufficient to maintain the NAAQS i ndefinitely into the future

. These programs will

, therefore

, constitute the attainment and maintenance plan for Ohio ' s portion of the Cincinnati

, OH-KY-IN area.

The enclosed information

, compiled by the Ohio Environmental Protection Agency (EPA)

, Ohio Department of Transportation

, and the Ohio

, Indiana and Kentucky Reg i onal Coun c il of

Governments ( associated p l anning organizat i on)

, shows s i g n ificant emission reductions in point and mobile sources since ambient violations have occurred. A signifi c ant portion of the improved air quality can be attributed to federal programs for the mob i le source sector

, the regional reductions associated with the transport programs

, and control strategies implemented by Ohio

, such as Low Reid Vapor Pressure Fuel requirements

.

The public hearing for this package was held on March, 3 2 016

, in Cincinnat i, Ohio and public comments were accepted through March, 3 2016 as well. The comments re c e i ved and

Oh i o EPA ' s r e sponse to those comments is included in this package

.

SO West Town Stree t • S ui te 700 • P .O. Box 1049 • Columbus, OH 43216-1049

epa.ohio.gov • (614) 644

- 3020 • (614) 644-3184 (fax)I am also requesting that this redesignation request be processed by U.S. EPA as expeditiously as possible due to the upcoming nonattainment designations for the 2015 ozone NAAQS

. These designations are scheduled to occur in October 2017 and the Cincinnati

, OHKY-IN area will potentially be designated nonattainment for the 2015 ozone NAAQS. It is vital

to Ohio and the Cincinnati area to reach attainment for the 2008 ozone NAAQS before this

time to avoid trigging any implications under the Clean Air Act for areas designated

nonattainment for a newer standard but have not been designated back to attainment for a
standard that has been revoked.

This submittal consists of one (1) hard copy of the required documentation. An exact duplicate

electronic version of the submittal in PDF format is available at http: // www.epa

. state

. oh

. us / dapc / SIP / 200 8 .aspx under the heading " Clean Data Requests, Redesignations and Maintenance Plans".

If you have any questions

, please contact Jennifer Van Vlerah in our Division of Air Pollution

Control at (614) 644-3696

.

Sincerely

,

# ~~ Craig W. Butler

Director

enclosures

cc : Robert Hodanbosi, DAPC

Jennifer Van Vlerah, DAPC

# REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR

THE OHIO PORTION OF THE

C INCINNATI , OH

- KY

- IN

8

- HOUR OZONE

NONATTAINMENT AREA

Butler, Clermont, Clinton, Hamilton

, and Warren Counties, Ohio

Prepared b y: Ohio Environmental Protection Agency

Divis ion of Air Pollution Control

April 2016Th is page left intentionally blanki 

### TABLE OF CONTENTS

Chapter One

Introduction

................................ ................................ ................................ ................................ ..... 1 Background

................................ ................................ ................................ ................................ ..... 1 Geographical description

................................ ................................ ................................ ................ 2 Status of air quality

................................ ................................ ................................ .......................... 3

Chapter Two Requirements for redesignation

................................ ................................ ................................ ...... 4

Chapter Three Ozone monitoring

................................ ................................ ................................ .......................... 11

Ozone NAAQS

................................ ................................ ................................ .............................. 11 Ambient data quality assured

................................ ................................ ................................ ........ 12 Three complete years of data

................................ ................................ ................................ ....... 12 Commitment to continue monitoring

................................ ................................ ............................. 16

Chapter Four

Emission i nventory

................................ ................................ ................................ ........................ 1 7

Base y ear i nventory

................................ ................................ ................................ ...................... 1 9

Emission p rojections

................................ ................................ ................................ ..................... 1 9

Demonstration of m aintenance

................................ ................................ ................................ ..... 1 9

Perm anent and e nf orceable e missions r eductions

................................ ................................ ...... 34

Provisions for f uture u pdates

................................ ................................ ................................ ........ 38

Chapter Five

Con trol measures and regulations

................................ ................................ ................................ 40

Em ission inventories/statements

................................ ................................ ................................ .. 40 Implementation of p ast SIP r evisions

................................ ................................ ........................... 40

New s ource r eview p ro v isions

................................ ................................ ................................ ..... 51

As surance of conti nued controls

................................ ................................ ................................ .. 51

Chapter Six

Con tingency measu res

................................ ................................ ................................ ................. 53 Commitment to revise plan

................................ ................................ ................................ ........... 53

Commitm ent for contingency measures

................................ ................................ ....................... 53

P otential contingency measures

................................ ................................ ................................ ... 54

List of VOC and NO

x sources

................................ ................................ ................................ ....... 5 6

Chapter Seven Modeling Analysis

................................ ................................ ................................ ......................... 5 7 Summary of Modeling Results for N ational Emission Control Strategies in Final Rulemaking

... 5 7 U.S. EPA Modeling Analysis for Interstate Transport “Good Neighbor” Provision

...................... 5 7 LADCO Modeling for Eight

- Hour Ozone Sta ndard

................................ ................................ ....... 60 Summary of Existing Modeling Results

................................ ................................ ........................ 61ii

Chapter Eight Public par ticipation

................................ ................................ ................................ ........................ 62

Chapter Nine

Conclusions

................................ ................................ ................................ ................................ ... 63iii FIGURES

Figure 1 Map of the Cincinnati, OH

- KY

- IN N onattainment A rea and M onitor L ocations

.... 1 2 Figure 2 Concentration Trends in CAR T Nodes

- Cincinnati

................................ .............. 3 6 Figure 3 Partial Regression Tree for Cincinnati

................................ ................................ . 3 8 Figu re 4 NOx Emissions from EGUs 2003

- 20 1 4

................................ ............................... 42iv TABLES

Table 1 Monitoring Data for Cincinnati

- OH

- KY

- IN 2012

– 2014

................................ ........ 1 4

Table 2 Emission Estimations for On

- r oad Mobile Sources for Butler Co ., Ohio

.............. 20

Table 3 Emission Estimations for O n

- road Mobile Sources for Clermont Co ., Ohio

........ 20

Table 4 Emission Estimations for On

- road Mobile Sources for Clinton C o ., Ohio

............ 20

Table 5 Emission Estimations for On

- road Mobile Sources for Hamilton Co. , Ohio

......... 20

Table 6 Emission Estimations for On

- road Mobi le Sources for Warren Co.

, Ohio

........... 20

Table 7 Emission Estimations for On

- road Mobile Sources for Dearborn Co

. , Indiana

.... 2 1

Table 8 Summary of Ohio and Indiana Emission Estimations for On

- Road Mobile Sources 2 1

Tab le 9 Emission Estimations for On

- road Mobile Sources for Boone Co., Kent ucky

..... 21

Table 10 Emission Estimations for On

- road Mobile Sources for Campbell Co., Kentucky

. 21

Table 1 1 Emission Estimations for On

- road Mobile Sources for Kenton Co., Kentucky

.... 21

Table 12 Summary of Kentucky Emission Estimations for On

- Road Mobile Sources

........ 21

Table 1 3 Emission Estimation s for On

- road Total Cincinnati

- OH

- KY

- IN Sources

.............. 22

Table 14 Mobile Vehicle Emission Budget for Ohio and Indiana

................................ ........ 22

Table 15 Mobile Vehicle Emission Budget for Kentucky

................................ ..................... 2 3

Table 1 6 NOx Emission Inventory Butler Co , Ohio

. ................................ ............................. 2 5

T able 1 7 NOx Emission Inventory Clermont Co., Ohio

. ................................ ...................... 2 5

Table 1 8 NOx Emiss ion Inventory Clinton Co., Ohio

. ................................ .......................... 2 5

Table 1 9 NOx E mission Inventory Hamilton Co., Ohio

. ................................ ....................... 2 6

Table 20 NOx Emis sion Inventory Warren Co., Ohio

. ................................ ......................... 2 6

Table 2 1 NOx Emis sion Inventory Dearborn Co ., Indiana

. ................................ .................. 2 6

Table 22 NOx Emission Inventory Boone Co., Kentucky

................................ .................... 2 7

Table 23 NOx Emission Inve ntory Campbell Co., Kentucky.

................................ .............. 2 7

Table 24 NOx Emission In ventory Kenton Co., Kentucky.

................................ .................. 2 7

Table 25 NOx Emission Inventory Cincinnati

- OH

- KY

- IN

, Total

................................ ........... 2 8

Table 2 6 VOC Emission Inventory Butler Co, Ohio.

................................ ............................ 2 9

Table 27 VOC Emission Inventory Clermont Co., Ohio.

................................ ...................... 2 9

Table 28 VOC Emission Inventory Clinton Co., Ohio.

................................ ......................... 2 9

Table 29 VOC Emission Inventory Hamilton Co., Ohi o.

................................ ...................... 30

Table 30 VOC Emissio n Inventory Warren Co., O hio.

................................ ........................ 30

Table 31 VOC Emission Inve ntory Dearborn Twp., Indiana.

................................ ............... 30

Table 32 VOC Emission Inventory Boone Co., Kentucky

................................ .................... 31

Table 33 VOC Emission Inve ntory Campbell Co., Kentucky.

................................ .............. 31

Table 34 VOC Emission In ventory Kenton Co., Kentucky.

................................ .................. 31

Table 35 VOC Emiss ion Inventory Cincinnati

- OH

- KY

- IN , Total

................................ .......... 32

Table 36 Projected E mission E stimates 2014

- 20 3 0 Cincinnati

- OH

- KY

- IN

......................... 32

Table 37 Combined C omparison of 2011 an d 2014 On

- road and EGU Totals

.................. 3 5

Table 3 8 U.S. EPA “Good Neighbor” Provision Modeling Results Average Design Values. 5 8

Table 39 U.S. EPA “Good Neighbor” Current Design Value

. ................................ .............. 59

Table 40 LADCO’s Modeling Results for the Cincinnati Area

. ................................ ............ 61v APPENDICES

A 2012

- 2014 Air Quality System (AQS ) Data and SLAMS Certification

B 2013

- 2015 Air Quality Syst em (AQS) Data

C Mobile Source Emissions Inventory

D LADCO Meteorology Analysis

E Public Participation Documentationvi This page left intentionally blank1

REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR THE

OHIO PORTION OF THE C INCINNATI

- , OH

- KY

- IN

OZONE NO NATTAINMENT AREA

Butler, Clermont, Clinton, Hamilton, and Warren Counties, Ohio



### CHAPTER ONE

I ntroduction The Clean Air Act (CAA) requires areas failing to meet the National Ambient Air Quality Standard (NAAQS) for ozone to develop State Implementation Plans (SIP’s) to expeditiously attain and maintain the standard. O n March 12,

2008 , the United States Enviro nmental Protection Agency ( U.S. EPA ) revised the air quality standard for ozone replacing the 19 97 eight

- hour standard of 0.08 parts per million ( ppm) with a more stringent standard of 0.075 ppm

.

On March 21, 2012 (77 FR 30088)

, U.S. EPA designated nonattainment areas

for the 2008 eight

- hour ozone standard. Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas to be redesig nated to attainment provid ed certain criteria are met. The following are the criteria that must be met in order for an area to be redesignated from nonattainment to attainment:

i) A determination that the area has attained the eight

- hour

ozone standard. ii) An approved State Implementation Plan (SIP) for the area

under Sectio n 110(k ). iii) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requireme nts. iv) A fully approved maintenance plan under Section 175(A). v) A determination that all Section 110 and Part D requirements

have been met.

Background

The current Cincinnati

, OH

- KY

- IN nonattainment area includes the following

Counties : Butler, Clermont, C linton, Hamilton, and Warren in Ohio ; Dearborn (partial nonattainment of Lawrenceburg Township only ) in Indiana ; and Boone, Camp b ell, and Kenton in Kentucky (partial nonattainment 1 )

.

1 Boone County (part) 2000 Census tracts: 702, 703.01, 703.04, 703.05, 703.06, 703.07, 703.08, 703.09, 704.01, 704.02, 705.01, 705.02, 706.01, 706.03, 706.04. Campbell Coun ty (part) 2000 Census tracts: 501, 502, 503, 504, 505, 506, 511.01, 511.02, 512, 513, 519.01,
519.03, 519.04, 520.01, 520.02, 521, 522, 523.01, 523.02, 524, 525, 526, 528, 529, 530, 531. Kenton County (part) 2000 Census tracts: 603, 607, 609, 610, 611, 612 , 613, 614, 616, 636.03,2

As part of the 1997 eight

- hour ozone standard designations

, the follow ing

C ounties within the Cincinnati

, OH

- KY

- IN area were designated as basic

nonattainment pursuant to Subpart 1 of the CAA and

, therefore

, were subject to nonattainment area rulemakings : Butler, Clermont, Clinton, Hamilton, and

Warren Counties in Ohio ; Boo ne, Campbell and Kenton Counties in Kentucky ; and Dearborn County (partial nonattainment of Lawrenceburg Township only )

in Indiana

. The Ohio portion of the Cincinnati , OH

- KY

- IN area was redesignated to attainment on May 11

, 20 10 ( 7 5 FR 26118 ). A maintena nce plan was approved at th at time

.

As a result of th e 2012 ozone designations for the 2008 eight

- hour ozone

standard

, U.S. EPA designated the Cincinnati , OH

- KY

- IN area marginal

nonattainment , pursuant to Subpart 2 of the CAA

, and Ohio Environmental

P rotection Agency ( Ohio EPA ) was required to submit certain nonattainment plan elements by July 20, 2014

. Ohio EPA submitted those elements on July
18, 2014 and U.S. EPA published a proposal and direct final action approving that submittal on March 10, 201 6 ( 81 FR 12626 and 81 FR 12591). The approval will be effective May 9, 2016, unless U.S. EPA receives adverse comments by April 11, 2016

.

T his document is intended to support Ohio’s request that the Ohio portions of

the Cincinnati

, OH

- KY

- IN area be redesi gnated from nona ttainment to attainment for the eight

- hour ozone s ta ndard

. In addition, the States of Kentucky and Indiana also intend to submit requests for their respective portions of the Cincinnati

, OH

- KY

- IN area. The Cincinnati

, OH

- KY

- IN area has

rec orded three (3) years of complete quality

- assured ambient air quality monitoring data for the years 20 12 through 20 14 dem onstrating attainment of the eight

- hour ozone standard.

Geographical Description

The Cincinnati

, OH

- KY

- IN eight

- hour ozone nonatta inment area is located in

southwest Ohio and includes the following C ounties of : Butler, Clermont, Clinton, Hamilton, and Warren in Ohio ; Dearborn (partial nonattainm ent of Lawrenceburg Township only ) in Indiana ; and partial areas 2 of Boone, Camp b ell, and Kenton in Kentucky

. This area is shown in Figure 1 under Chapter Three

.

636.04, 636.05, 636.06, 638, 640, 641, 642, 643, 644, 645, 646, 647, 648, 649, 650, 651, 652,
653, 654, 655.01, 655.02, 656, 657, 658, 659, 668, 669, 670, 671.

2 Boone County (part) 2000 Census tracts: 702, 703.01, 703.04, 703.05, 703.06, 703.07, 703.08, 703.09, 704.01, 704.02, 705.01, 705.02, 706.01, 706.03, 706.04. Campbell County (part) 2000 Census tracts: 501, 502, 503, 504, 505, 506, 511.01, 511.02, 512, 513, 519.01,
519.03, 519.04, 520.01, 520.02, 521, 522, 523.01, 523.02, 524 , 525, 526, 528, 529, 530, 531. Kenton County (part) 2000 Census tracts: 603, 607, 609, 610, 611, 612, 613, 614, 616, 636.03,
636.04, 636.05, 636.06, 638, 640, 641, 642, 643, 644, 645, 646, 647, 648, 649, 650, 651, 652,
653, 654, 655.01, 655.02, 656, 657, 658, 659, 668, 669, 670, 671.3

Status of Air Quality Ozone monitoring data for the m ost recent three (3) years, 20 12 through 20 14

, demonstrate that the air quality has m et the NAAQS for ozone in this marginal nonattainment area. The NAAQS attainment, accompanied by decreases in

emission lev els discussed in Chapter F our, supports a redesignation to

attainment for the Cincinnati

, OH

- KY

- IN area based on the requirements in Section 107(d)(3)(E) of the CAA

.4



### C HAPTE R TWO

Requirements for Redesignation

U.S. EPA has published detailed guidance in a document entitled Procedures for Processing Requests to Redesignate Areas to Attainment ( R edesignation

G uidance ), issued September 4, 1992 , to Regional Air Directors. Th e redesignation request and maintenance p lan are based on the R edesignation

G uidance, supplemented with additional guidance re ceived from staff of U.S.

EPA Region V.

Below is a summary of each redesignation criterion as it applies to the

Cincinnati

, OH

- KY

- I N area.

i.) Attainment of the standard

- CAA Section 107 (d)(3)(E)(i) There are two components involved in making this

demonstration . The first component relies on ambient air quality

data. The data that are used to demonstrate attainment should

be the product of ambient monitoring that is representative of the area of highest concentration. The data should be collected and quality

- assured in accordance with 40 CFR 58 and recorded in

the Air Quality System (AQS) in order for it to be available to the

pu blic for review. Chapter Three discusses this requirement in

more detail

The second component relies upon supplemental U.S. EPA

approved air quality modeling. The supplemental modeling is not required for ozone nonattainmen t areas seeking redesignation ; h owever, Ohio EPA has incorporated photochemical modeling information in Chapter Seven to further
support our request that Ohio ’s portion of the nonattainment area be redesignated to attainment

.

ii.) SIP approval

- CAA Section 107 (d)(3)(E)(ii)

The SIP for the area must be fully approved under Section 110(k) and must satisfy all the requirements that apply to the area. Ohio’s SIP was approved on May 4 , 1994 (59 FR 23799)

, and March 23 , 1995 (60 FR

15235 ) and includes the Cincinnati

, OH

- KY

- IN area. In addi tion, on July 18, 2014, Ohio EPA submitted a SIP revision for this area and U.S.

EPA published a proposal and direct final action approving that submittal on March 10, 2016 ( 81 FR 12626 and 81 FR 12591). The approval will be effective May 9, 2016, unless U .S. EPA receives adverse comments by April 11, 2016

. Chapter F ive discusses this requirement in more detail

.

iii.) Permanent and enforce able improvement in air quality

- CAA

Section 107 (d)(3)(E)(iii)5

The state must be able to reasonably attribute the i mprovement in air quality to emission reductions which are permanent and enforceable. The state should estimate the percent reduction

achieved from federal measures as well as control measures that have been adopted and implemented by the state.

On March 6, 2015, U.S. EPA finalized the “ Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements; Final Rule” (herein referred to as “Implementation Rule”). (80 FR 12264) In the Implementation Rule, U.S. EPA states “Under CAA section 182(a), Marginal areas have up to 3 years from the effective date of designation to attain the NAAQS, and are not required to submit an attainment demonstration SIP.” (80 FR 12268) Further, U.S. EPA identifies “ An attainmen t demonstration consists of: (1) Technical analyses, such as base year and

future year modeling of emissions which identifies sources and quantifies emissions from those sources that are contributing to nonattainment; (2) analyses of future year emissions reductions and air quality improvement resulting from existing ( i.e., already adopted or ‘‘on the books’’) national, regional and local programs, and potential new local measures needed for attainment, including RACM and RACT for the area; (3) a list of

ad opted measures (including RACT) with schedules for implementation and other means and techniques necessary and appropriate for demonstrating attainment as expeditiously as practicable but no later than the outside attainment date for the

area’s classificat ion; and (4) a RACM analysis to determine whether any additional RACM measures could advance attainment by 1 year. ” (80 FR 12268) Therefore, these requirements, and specifically, the requirement to adopt specific state measures beyond federal measures, are not applicable to marginal areas, such as the Cincinnati, OH

- KY

- IN nonattainment

area.

Regardless, Ohio has adopted and implemented control

measures for these c ounties in th e area beyond the federal

measures in order to comply with the 1997 eight

- hour o zone standard and Ohio also adopted the initial 1979/1981 s tatewide

rules. These measures and rules remain in effect and have

assisted the Cincinnati

, OH

- KY

- IN area in reach ing attainment

for the 2008 eight

- hour ozone standard. Below is a list of

severa l previously adopted Ohio rules that have contributed to reducing ozone in this area :

 Portable Fuel Containers requirements6

 Architectural and Industrial Maintenance (AIM) Coatings

rules

 Consumer Products rules

 Clean Air Interstate Rule (CAIR)

 NO

x Sip Cal l rules

C hapters F our and F ive discuss this requirement in more detail.

iv.) Section 110 and Part D requirements

- CAA Section 107 ( d)(3)(E)( v) For purposes of redesignation, a state must meet all requirements of Section 110 and P art D that were applica ble prior to submittal of the complete redesignation request.

i.) Section 110(a) requirements Section 110(a) of Title I of the CAA contains the general requirements for a SIP. Section 110(a)(1) generally directs states to submit a SIP that provide s for implementation, maintenance, and enforcement of the air quality standards to the U.S. EPA after reasonable notice and public hearing. Section 110(a)(2) provides that the infrastructure SIP submitted by a state must have been adopted by the state aft er reasonable public notice and hearing, and that, among other things, it must include

enforceable emission limitations and other control

measures [3 ]

, means or techniques necessary to meet the requirements of the CAA; provide for establishment and operati on of appropriate devices, methods, systems and procedures necessary to monitor ambient air quality; provide for implementation of a source permit program to regulate the modification and construction of any stationary source within the areas covered by th e plan; include provisions for the implementation of P art C,

p revention of s ignificant d eterioration (PSD) and P art D, NSR permit programs; include criteria for stationary

source emission control measures, mon itoring, and reporting; include provisions for air quality modeling; and provides for public and local agency participation in planning and emission control rule development. In

Ohio’s December 27 , 20 12 infrastructure SIP submission,

Ohio verified that the S tate fulfills the requirements of

Section 110 (a)(2) of the Act.

Subpart 1 of Part D, found in Sections 172

- 176 of the CAA, sets

[3 Other than nonattainment emission limitations and measures which are a part of nonattainment area plans and subject to the timing requirements of Section 172 of the CAA.7

forth the basic nonattainment requirements applicable to all areas which are designated nonattainment based on a violation of the NAAQS. Subpart 2 of Part D, which includes Section 182 of the CAA, establishes more specific requirements depending

on the area’s ozone nonattainment classification.

The Cincinnati, OH

- KY

- IN area was designated under Subpart 2

of Part D as a marginal nonattainment area for ozone as part of

U. S . EPA “Air Quality Designations for the 2008 Ozone

NAAQS .” (77 FR 30088) Therefore, the Cincinnati, OH

- KY

- IN area must meet the applicable requirements of both Subpart 1 and Subpart 2 of Part D. The applicable Subpart 1 requirements

are contained in Sec tion 172(c)(1)

- (9) and in Section 176. The applicable Subpart 2 requirements are contained in Section 182(a) (marginal nonattainment area requirements).

ii.) Subpart 1 of Part D

- Section 172(c) requirements Section 172(c)(1) requires the plans for a ll nonattainment areas to provide for the implementation of all RACM as expeditiously as practicable and to provide for attainment for the national primary ambient air quality sta ndards. As

discussed abo ve, U.S. EPA’ s Implementation Rule did not require ma rginal nonattainment areas to implement RACT/RACM. In addition, because attainment has been

reached in the Cincinnati, OH

- KY

- IN area , no additional measures are needed to provide for attainment.

The reasonable further progress ( RFP ) requirement

under se ction 172(c)(2) is defined as progress that must

be made toward attainment. This requirement is not relevant for purposes of redesignation because the Cincinnati, OH

- KY

- IN area is monitoring attainment of the

2008 eight

- hour ozone standard

. In addition, because

the Cincinnati, OH

- KY

- IN area has attained the ozone

standard and is no longer subject to an RFP requirement, the section 172(c)(9) contingency measures are not applicable for purposes of redesignation.

Section 172(c)(3) requires submission and a pproval of a comprehensive, accurate and current inventory of actual

emissions. This requirement was superseded by the inventory requirement in S ection 182(a)(1) discussed

below.

Section 172(c)(4) requires the identification and quantification of a llowable emissions for major new and modified stationary sources in an area, and S ection8 172(c)(5) requires source permits for the construction and operation of new and modified major stationary sources anywhere in the nonattainment area. Ohio has a fully approved new source review program which is discussed

in more detail under Chapter Five.

Section 172(c)(6) requires the SIP to contain control measures necessary to provide for attainment of the

standard. Because attainment has been reached, no

additi onal measures are needed to pro vide for

attainment.

Section 172(c)(7) requires the SIP to meet the applicable provisions of S ection 110(a)(2). The Ohio SIP meets the requirements of S ection 110(a)(2) for purposes of redesignation, as discussed above.

i i i.) Subpart 1 of Part D

- Section 176(c) requirements Section 176(c) of the CAA requires states to establish criteria and procedures to ensure that Federally

supported or funded activities, including highway projects, conform to the air quality plannin g goals in the applicable

SIPs. The requirement to determine conformity applies to transportation plans, programs and projects developed, funded or approved under T itle 23 of the U.S. Code and the Federal Transit Act (transportation conformity) as well

as to all other Federally

- supported or funded projects (general conformity). State conformity revisions must be consistent with Federal conformity regulations relating to consultation, enforcement, and enforceability, which U.S. EPA promulgated pursuant to CAA requirements.

Ohio EPA established two SIPs for conformity. The rules in Ohio Administrative Code (OAC) C hapter 3745

- 101 contained Ohio’s SIP approved rules for transportation conformity, and OAC C hapter 3745

- 102 contained Ohio’s SIP approved rules f or general conformity.

Ohio EPA’s transportation conformity rules in OAC Chapter 3745

- 101 were approved as a part of Ohio’s SIP on July 31, 2000 ( 65 FR 34395 ) and April 27, 2007 (72

FR 20945 ). However, Ohio’s transportation conformity rules in OAC Chapter 3745

- 101 were completely removed from Ohio’s SIP on March 2, 2015 (80 FR 11134) when the rules were replaced by a series of memorandums of understanding (MOUs) between Ohio9 EPA, U

. S

. E PA, and the various state and local agencies involved in the transporta tion conformity process. The currently effective MOUs are available on Ohio EPA’s

website at: http://epa.ohio.gov/dapc/sip/trans_conform.aspx

.

Ohio EPA’s general conformity rules in OAC C hap ter

3745

- 102 were approved as part of Ohio’s SIP on March 11, 1996 (61 FR 9644 ). In April, 2010, U

. S

. EPA promulgated changes to 40 CFR 51.851. The language in paragraph (a) of the section was changed from “must” to “may”, thereby eliminat ing the requireme nt for states to

maintain a g eneral c onformity SIP. For this reason, Ohio EPA requested, and U

. S

. EPA granted rescission of Ohio’s general conformity SIP. The rules in OAC Ch apter

3745

- 102 were removed from the state SIP on May 26, 2015 (80 FR 29968)

. The state SIP was replaced by the federal rules in 40 CFR Part 93, subpart B.

iv.) Subpart 2 of Part D

- Section 182(a) requirements Section 182(a)(1) requires the submission of a comprehensive emissions inventory. This requirement is addressed under Chapt er Four

.

Section 182(a)(2) requires the submission of certain

corrections to VOC RACT rules, inspection and

maintenance programs and permitting programs. These

corrections were addressed for the Cincinnati, OH

- KY

- IN

area under the one

- hour ozone standar d and do not need to be addressed again under the 2008 eight

- hour

standard.

Section 182(a)(3)(B) requires the submission of an

emission statement SIP. This requirement is addressed under Chapter Five

.

v.) Maintenance plans

- CAA Section 107 (d)(3)(E)( i v ) Section 107(d)(3)(E) stipulates that for an area to be redesignated, U.S. EPA must fully approve a maintenance plan

that meets the requirements of Section 175(A). The maintenance plan must constitute a SIP revision and must provide for maintenance of t he relevant NAAQS in the area for

at least 10 years after redesignation. Section 175 (A) further states that the plan shall contain such additional measures, if any, as may be necessary to ensure such maintenance.10

In addition, the maintenance plan shall contain such contingency measures as the Administrator deems necessary to ensure prompt correction of any violation of the NAAQS. At a minimum, the contingency measures must include a requirement that the state will implement all measures contained in the nonattainment SIP prior to redesignation.

States seeking redesignation of a nonattainment area should consider the following provisions:

a.) a ttainment inventory ; b.) m aintenance demonstration ; c.) m onitoring network ; d.) v erification of continued a ttainment ; and e.) c ontingency plan

.
Chapter S ix discusses this requirement in more detail.11



### CHAPTER THREE

OZONE MONITORING CAA Section107 (d)(3)(E)(i)

Requirement 1 of 4 A demonstration that the NAAQS for ozone, as published in 40 CFR 50. 15,

has b een attained.

Background

There are eleven monitor s measuri ng ozone concentrations in

this no nattainm ent area. Nine of the eleven monitors , located in Ohio, are o perated by Ohio EPA Division of Air Pollution Control,

Southwest District Office and the Ha milton County Division of

Environmental Services

. A listing of the design values based on

the three

- year average of the annual fourth highest daily maximum eight

- hour average ozone concentration s from 20 12 through 20 14 certified air quality data is shown in Table 1

. In addition, concentrations from 2013 through 2015 are also shown. This newer 2015 data will be certified by May 1, 2016.

The locations of the monitoring sites for this nonattainment area

are shown on Figure 1

.12

D emonstration

Figure 1

- Map of the Cincinnati

, OH

- KY

- IN nonattainment area and

monitor locations

Requirement 2 of 4 Ambient monitoring data quality assured in accordance with 40 CFR 58.10,

recorded in the U.S. EPA air quality system (AQS) data base, and available for publ ic view.

Demonstration

The Ohio EPA has quality assured all 2012 through 2014 data shown in Appendix A in accordance with 40 CFR 58.10 and the Ohio Quality Assurance Manual. Ohio EPA has recorded the data
in the AQS database and

, therefore , the data are available to the public. All 2015 data included in Appendix B will be quality assured by May 1, 2016.

R equirement 3 of 4 A showing that the three

- year average of the fourth highest values, based on data from all monitoring sites in the area or its aff ected downwind environs, are13

below 75 parts per billion (ppb). ( This showing must rely on three complete, consecutive calendar years of quality assured data. )

Background The following information is taken from Appendix P

,

“ Interpretation of the Primary and Secondary NAAQS for O 3 ” of

40 CFR Part 58.

Three complete years of ozone monitoring data are required to demonstrate attainment at a monitoring site. The eight

- hour primary and secondary ozone ambient air quality standards are met at an ambient air q uality monitoring site when the three

- year average of the annual fourth

- highest daily maximum eight

- hour average ozone concentration s is less than or equal to 0.075 ppm. When this occurs, the site is said to be in attainment. Three significant digits mus t be carried in the computations. Because the third decimal digit, in ppm, is truncated, 0.075666* ppm is the largest concentration that is less than or equal to 0.075 ppm. Therefore, for the purposes of this request, values

below 0.0757 ppm meet the sta ndard. These data handling procedures are applied on an individual basis at each monitor in the area. An area is in compliance with the eight

- hour ozone NAAQS if, and only if, every monitoring site in the area meets
the NAAQS. An individual site's three

- year average of the annual fourth highest daily maximum eight

- hour average ozone concentration s is also c alled the site's design value.

Table 1 shows the monitoring data for 20 12

– 20 14 and 2013

- 2015 that were retrieved from the U.S. EPA AQS. The air

qua lity design value for the area is the highest design value among all sites in the area. Please note that the standard is measured in ppm while the commonly used unit is ppb. For the remainder of this document, ppb will be used.14

D emonstration

Table 1

- M onitoring Data for the Cincinnati

, OH

- KY

- IN , OH a rea
for 20 12

– 20 14 (certified) and 2013

– 2015

Data source: U. S. EPA Air Quality System (AQS)

http://www.epa.gov/aqs

SITE ID COUNTY YEAR %OBS 1 st 2 nd 3 rd 4 th 2012

- 2014 2013

-

2015

8

- HR 8

- HR 8

- HR 8

- HR AVE R. AVER

. 39

- 017

- 0004 Butler 2012 100 95 90 89 83

73 69 39

- 017

- 0004 Butler 2013 98 70 70 69 68

39

- 017

- 0004 Butler 2014 99 80 72 71 70

39

- 017

- 0004 Butler 2015 94 74 71 70 70

39

- 017

- 0018 Butler 2012 95 88 87 85 84

73 69 39

- 017

- 0018 Butler 2013 100 76 70 68 68

39

- 017

- 0018 Butler 2014 99 75 73 71 69

39

- 017

- 0018 Butler 2015 100 71 70 70 70

39

- 017

- 9991 Butler 2012 93 97 88 87 85

74 68 39

- 017

- 9991 Butler 2013 94 75 73 69 69

39

- 017

- 9991 Butle r 2014 94 74 72 71 69

39

- 017

- 9991 Butler 2015 88 73 72 69 68

39

- 025

- 0022 Clermont 2012 100 107 97 94 91

75 68 39

- 025

- 0022 Clermont 2013 100 78 69 66 66

39

- 025

- 0022 Clermont 2014 98 70 69 68 68

39

- 025

- 0022 Clermont 2015 99 81 75 71 70

39

- 027

- 1002 Clinton 2012 100 100 91 87 86

73 68 39

- 027

- 1002 Clinton 2013 99 77 69 65 64

39

- 027

- 1002 Clinton 2014 99 77 71 70 70

39

- 027

- 1002 Clinton 2015 100 76 73 71 70

39

- 061

- 0006 Hamilton 2012 96 98 96 92 87 75 70

39

- 061

- Hamilton 2013 95 74 70 69 6915

SITE ID COUNTY YEAR %OBS 1 st 2 nd 3 rd 4 th 2012

- 2014 2013

-

2015

8

- HR 8

- HR 8

- HR 8

- HR AVE R. AVER

. 0006

39

- 061

- 0006 Hamilton 2014 96 83 72 71 70

39

- 061

- 0006 Hamilton 2015 97 86 77 74 72

39

- 061

- 0010 Hamilton 2012 87 90 85 85 83

73 69 39

- 061

- 0010 Hamilton 2013 97 73 71 69 64

39

- 061

- 0010 Hamilton 2014 100 76 75 74 73

39

- 061

- 0010 Ham ilton 2015 100 80 72 71 70

39

- 061

- 0040 Hamilton 2012 100 96 83 82 82

73 69 39

- 061

- 0040 Hamilton 2013 99 74 73 72 69

39

- 061

- 0040 Hamilton 2014 100 78 74 69 69

39

- 061

- 0040 Hamilton 2015 99 75 73 72 71

39

- 165

- 0007 Warren 2012 100 92 89 84 80

72 6 9 39

- 165

- 0007 Warren 2013 99 74 72 71 67

39

- 165

- 0007 Warren 2014 100 74 73 71 71

39

- 165

- 0007 Warren 2015 100 79 78 72 71

21

- 015

- 0003 Boone 2012 100 85 83 78 74

65 61 21

- 015

- 0003 Boone 2013 100 71 62 60 59

21

- 015

- 0003 Boone 2014 100 64 64 62 6 2

21

- 015

- 0003 Boone 2015 87 71 69 62 62

21

- 037

- 3002 Campbell 2012 99 106 89 84 84

75 71 21

- 037

- 3002 Campbell 2013 100 79 76 72 72

21

- 037

- 3002 Campbell 2014 99 74 74 72 71

21

- 037

- 3002 Campbell 2015 87 79 78 77 71

The area's design value s ha ve tr ended downward as emissions have

declined due to such factors as cleaner automobiles and fuels

, along

with controls for electric generating units ( EGUs )

, both regionally and locally.16

Requirement 4 of 4

A commitmen t that once redesignated, the s tat e will continue to operate an appropriate monitoring network to verify the maintenance of the attainment

status.

Demonstration

Ohio EPA commit s to continue moni toring ozone levels at the

Ohio site s indicated in Figure 1 . Ohio EPA will consult with U.S.

EPA Region V prior to making changes to the existing monitoring network, should changes become necessary in the future. Ohio EPA will continue to quality assure the monitoring data to meet the requirements of 40 CF R 58 and all other federal requirements. Connection to a central station and updates to the Ohio EPA w eb site 4 will provide real time availability of the data and knowledge of any exceedances. Ohio

EPA will enter all data into AQS on a timely basis in accordance with federal guidelines.17



### CHAPTE R FOUR

EMISSION INVENTORY

CAA Section 107 (d)(3)(E)(iii) , & 1 07 (d)(3)(E)( v )

U.S. EPA ’s R edesignation G uidance requires the submittal of a comprehensive inventory of ozone precursor emissions (VOC and NO

x ) representative of the year when the area achieve s attainment of the ozone air quality standard. Ohio also must demonstrate that the improvement in air quality between the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emission reductions

. O ther emission inventory related requirements include a projection of the

emission invent ory to a year at least 10 years following redesignation; a demonstration that the projected level of emissions is sufficient to maintain the
ozone standard; and a commi tment to provide future updates of the inventory to enable tracking of emis sion levels during the 10

- year maintenance period.

The emissions inventory development and emissions projection discussion

below , with the exception of the mobile (on

- road) emissio ns inventory and projections, identifies procedures used by Indiana Department of Environmental Management (IDEM), Ohio EPA and the Kentucky Division of Environmental Quality (KDEQ)

, regarding emissions from the Cincinnati

, OH

KY

- IN area. Mobile source em issions were developed in conjunction with the Ohio, Kentucky, Indiana, and the Council of Governments (OKI)

. Specific

emissions data are provided for all counties , including those in Ohio, Kentucky

and Indiana.

Area, non

- road, on

- road and point sourc e emissions were compiled as follows:

 Area, non

- road and point emissions (EGUs, non

- EGUs and airport related emissions (AIR)) were collected from the data available on U.S. EPA’s Emissions Modeling Clearinghouse website 3

. 4 Using Ozone
NAAQS Emissions Mod eling platform (2011v6.1) data were collected together for the 2011 National Emissions Inventory (NEI) year and the

2018 and 2025 U.S. EPA

- projected inventories. Therefore, 2011 point emissions are actual reported emissions from the 2011 NEI.

 Because the 2 014 NEI is not available at this time, Ohio EPA, IDEM
and KDEQ derived 2014 actual point emissions (for EGUs and non

EGUs) from state inventory databases (e.g., Ohio’s EIS database which

serves as the basis for the 2014 NEI ).

 Because all emissions from s tate inventory databases, the NEI and the Ozone NAAQS Emissions Modeling platform (2011v6.1) are annual totals, t ons per summer day were derived according to the U.S. EPA guidance document Temporal Allocation of Annual Emissions Using

4 http://www.epa.gov/ttn/chief/emch/index.html18

EMCH Temporal Profile s , dated April 29, 2002 5

, using the temporal allocation references accompanying the 20111v6.1 modeling inventory

files. These files provide SCC specific profiles that allow annual emission totals to be distributed across various temporal periods, as

descr ibed in the guidance document referenced here.

 Using the above datasets:

o 2014 emissions for area, non

- road and AIR point were derived by interpolat ing between 2011 and 2018 . Note that Ohio EPA, KDEQ nor IDEM require airport related emissions to be report ed and therefore, actual 2014 airport emissions will not be available

until the 2014 NEI is available. If those emissions differ appreciably from the emissions projected using this methodology, Ohio EPA will commit to submitting a redesignation request and maintenance plan.

o 2020 emissions for area, non

- road and point (EGU, non

- EGU and AIR) were derived by interpolating between 2018 and 2025

.

o 2030 emissions for area, non

- road and point (EGU, non

- EGU and AIR) were derived using the TREND function in Microsoft Excel. If the TREND function resulted in a negative value, the emissions were assumed to not change.

 Mobile source emissions for all years were developed in conjunction

with OKI and were calculated from emission factors produced by U.S.

EPA’s 2014 Moto r Vehicle Emission Simulator (MOVES) software program and data extracted from the region’s travel

- demand model. Appendix C contains detailed methodology and data for mobile source emissions for all years.

 KDEQ emissions for all years are based upon the p artial nonat tainment area in each Kentucky C ounty comprising this nonattainment area, except AIR point emissions which are for the entire counties. EGU and

non

- EGU emissions are based upon the actual location of sources within the partial areas. Area and non

- road were best

- represented using calculated nonattainment portions of 57% (Boone), 56% (Campbell), and 54% (Kenton) . To make these nonattainment portion calculations for each county, the measurement function in Google Earth was employed

.

 IDEM emissio ns for all years are based upon the entire county except

for on

- road emissions are comprised of emissions from only the partial

nonattainment area in Dearborn C ounty

.

 Biogenic emissions are not included in these summaries.

Ohio recognizes that revisio ns to the emissions data below may be necessary once Kentucky and Indiana prepare a redesignation request and maintenance plan for their portion of the nonattainment area.

5 https://www3.epa.gov/ttn/chief/emch/temporal/index.html19

Requirement 1 of 5 A comprehensive emission inventory of the precursors of ozone completed for the base year.

Background The point source data are taken from Ohio's annua l emissions reporting program.

Periodic inventories, which include emissions from all sectors

- mobile, area, non

- road, and point sources

- are prepared every

thr ee years.

Demonstration

The 20 11 inventory is used as the nonattainment base year for the purpose of this submittal 6

. The 2014 inventory is used as the attainment year inventory for the purposes of comparison. These inventories represent a comprehensive, accurate, and current inventory of actual emissions from all sources of the relevant pollutants in the Cincinnati, OH

- KY

- IN area. Emissions of VOC

and NOx for 20 11 and 2014 are identified under Requirement Three of this Chapter.

Requirement 2 of 5 A pro jection of the emission inventory to a year at least 10 years following redesignation.

Background As discussed above, IDEM , KDEQ, OKI and Ohio EPA prepare d

a projected emissions inventory for the Cincinnati

, OH

- KY

- IN

area including area, non

- road, mobile, and point sources for precursors of ozone ( VOCs and NO

x ) for the nonattainment

area.

Demonstration In consultation with U.S. EPA and other stakeholders, Ohio EPA selected the year 2030 as the maintenance year for this redesignation request. The reque st also contains projected

emission inventories for 2020.

6 On July 18, 2014, Ohio EPA submitted its 2008 base year inventory as required under CAA Section 182(a)(1). Ohio EPA is not requesting that inventory be replaced with the 2011 inventory in this submittal in Ohio’s SIP.20

On

- Road Mobile Emission Estimations

Table s 2 through 13 contain the results of the emissions anal ysis for the appropriate years. All emissions estimations are expressed in tons per summer day ( TSD).

Table 2

- Butler County

, Ohio Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 10.21 7.59 4.79 2.88
NOx (TSD) 12.24 8.85 4.74 2.44
VMT (miles/day) 8,310,016 8,410,655 8,605,779 8,996,125

Table 3

- Clermont Cou nty

, Ohio Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 6.27 4.66 2.94 1.77 NOx (TSD) 7.52 5.44 2.91 1.50 VMT (miles/day) 5,104,068 5,165,881 5,285,728 5,525,481

Table 4

- Clinton County

, Ohio Emission Estimations f or

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 2.27 1.53 0.93 0.71 NOx (TSD) 4.53 3.51 1.86 1.28 VMT (miles/day) 1,867,870 2,004,092 2,172,898 2,531,300

Table 5

- Hamilton County

, Ohio Emission Estimations for

On

- Road Mobile Sources

2 0 11 20 14 20 20 20 30 VOC (TSD) 28.09 20.88 13.18 7.92
NOx (TSD) 33.69 24.37 13.05 6.71
VMT (miles/day) 22,870,707 23,147,685 23,684,703 24,759,009

Table 6

- Warren County

, Ohio Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30

VOC (TSD) 8.21 6.10 3.85 2.32

NOx (TSD) 9.84 7.12 3.81 1.96
VMT (miles/day) 6,683,481 6,764,422 6,921,354 7,235,29721

Table 7

– Dearborn County , Indiana Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 0.86 0.64 0.40 0. 24

N Ox (TSD) 1.03 0.74 0. 40 0. 21

VMT (miles/day) 698,492 706,951 723,352 756,163

Table 8

– Summary of Ohio and Indiana Emission Estimations

f or On

- Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 55.91 41.40 26.09 15. 84 NOx (TSD) 68.85 50.03 26.77 14. 1 0
VMT (miles/day) 45,534,634 46,199,686 47,393,814 49,803,375

Table 9

- Boone County

, Kentucky Emission Estimations for On

Road Mobile Sources

20 11 20 14 20 20 20 30
VOC (TSD) 3.30 2.53 1.38 0.77

NOx (TSD) 6.90 5.46 2.41 1.05
VMT (miles/day) 3,706,116 3,844,287 4,113,420 4,626,949

Table 10

- Campbell County

, Kentucky Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30
VOC (TSD) 2.05 1.58 0.86 0.48
NOx (TSD) 4.30 3.41 1.50 0.65
VMT (miles/day) 2,310,234 2,396,364 2,564,129 2,884,2 41

Table 11

- Kenton County

, Kentucky Emission Estimations for

On

- Road Mobile Sources

20 11 20 14 20 20 20 30

VOC (TSD) 3.12 2.39 1.30 0.73
NOx (TSD) 6.53 5.17 2.28 0.99
VMT (miles/day) 3,507,534 3,638,302 3,893,013 4,379,027

Table 12

– Summary of Ken tucky Emission Estimations for On

-

Road Mobile Sources

20 11 20 14 20 20 20 30 VOC (TSD) 8.47 6.50 3.54 1.98
NOx (TSD) 17.73 14.04 6.19 2.69
VMT (miles/day) 9,523,884 9,878,953 10,570,562 11,890,21722

Table 13

- Emission Estimation Tota ls for On

- Road Mobile

Sources for the Cincinnati

- OH

- KY

- IN A rea

20 11 20 14 20 20 20 30 VOC (TSD) 64.38 47.90 29.63 17.82
NOx (TSD) 86.58 64.07 32.96 16.79
VMT (miles/day) 55,058,518 56,078,639 57,964,376 61,693,592

Motor Vehic le Emission Budget

Table 14 and Table 15 contain the motor vehicle emissions budget s for the Cincinnati

, OH

- KY

- IN area

. For planning purposes, budgets are established for the combined Ohio and Indiana portions and for the separate Kentucky portion.

Tabl e 14

- Mobile Vehicle Emission s Budget for Ohio and

Indiana

20 20

Estimated

Emissions 20 20

Mobile Safety Margin

Allocation* 20 20

Total

Mobile Budget 20 30

Estimated

Emissions 20 30

Mobile Safety Margin

Allocation* 20 30

Total

Mobile Budget

VOC (TSD) 26. 09 3

. 91 30. 00 15. 84 2. 38 18. 22

NOx (TSD) 2 6.77 4. 0 2 3 0.7 9 14. 10 2. 12 16. 22

VMT (miles/day) 47,393,814

- - 49,803,375

- -

*The 15 percent margin of safety was calculated by taking 15
percent of the mobile source emission estimates.

Th e above budget s for th e Ohio and Indiana portion of the area, agreed upon as part of the interagency consultation process,

include the emission estimates calculated for 2020 and 20 30 (from Table 8) with an additional 15 percent margin of safety

allocated to those estimates

.

In an effort to accommodate future variations in travel demand

models and VMT forecast when no change to the network is planned, Ohio EPA consulted with U

. S

. EPA to determine a reasonable approach to address this variation. Based on this discussion, a 15 percent margin of safety allocation was agreed

upon and has been added to the emissions estimates for the Ohio and Indiana portions of this nonattainment area.23 Table 15

- Mobile Vehicle Emissions Budget for Kentucky

The above budget for the Kentucky portion of the area was provided directly by Kentucky as part of the consultation process and also includes a margin of safety allocated to the emission

estimates calculated for 20 20 and 20 3 0 ( from Table 12)

.

The emission estimates are derived from the travel demand

model and MOVES201 4 as described above

. All methodologies, the latest planning assumptions

, and the safety margins allocations were determined through the interagency consultation process descr ibed in the Transportation Conformity

Memorandum o f Understanding (MOU) among OKI, Ohio DOT,

and Ohio EPA.

A 15 percent margin of safety is appropriate because : 1) there is an acknowledged potential variation in VMT forecast and potential estimated mobil e source emissions due to expected modifications to TDM and mobile emissions models; and 2) t he

total decrease in emissions from all sources is sufficient to

accommodate this 15 percent allocation of safety margin to mobile sources while still continuing t o maintain the total

emissions in the Cincinnati

, OH

- KY

- IN area well below the 20 14

attainment level of emissions.

The 15 percent margin of safety was calculated for the Ohio and Indiana portions of this nonattainment area by taking 15 percent

of the mob ile source emission estimates. The 15 percent margin of safety was calculated by KDEQ using a different methodology for the Kentucky portion. KDEQ’s redesignation request and maintenance plan explains their methodology in

detail. Safety margin, as defin ed by the conformity rule, looks at

the total emissions from all sources in the nonattainment area.

The actual allocation is less than 15 percent of the total emission

reduction from all sources as can be seen from Table 36.

In summary, f or all three s ta tes combined, t he mobile budget 20 20

Estimated

Emissions 20 20

Mobi le Safety Margin

Allocation 20 20

Total

Mobile Budget 20 30

Estimated

Emissions 20 30

Mobile Safety Margin

Allocation 20 30

Total

Mobile Budget

VOC (TSD) 3. 54 0. 5 7 4. 11 1.98 0. 84 2. 82

NOx (TSD) 6. 19 1.20 7. 39 2.69 1.68 4.37

VMT (miles/day) 10,570,562

- - 11 ,890,217

- -24

safety margin allocation translates into :

-- An a llocation of 4. 4 8 TSD for VOC and 5.22 TSD for

NOx for 20 20 ; and

- A n allocation of 3.22 TSD for VOC and 3.80 TSD for NOx

for 20 30

.

When compared to the overall safety margi n, as defined in 40

CFR 93.101 7

, discussed under “Requirement 3 of 5” below, it is evident this allocation is significantly below the total safety margin for this area (see Table 36)

.

The current eight

- hour budgets will no longer be applicable

either afte r the effective date of the approved redesignation or after the effective date of any U.S. EPA action approving a finding that the new eight

- hour conformity budget included in this submittal is adequate for transportation conformity purposes

, whichever dat e comes first.

Requirement 3 of 5 A demonstration that the projected level of emissions is sufficient to maintain

the ozone standard.

Background

Maintenance is demonstrated when the future

- year (2030) projected emission totals are below the 2014 attai nment year

totals.

Sectors included in the following tables are: Electrical Generating Unit (EGU) ; Non

- Electrical Generating Unit (Non

EGU) ; Airport (Air); Non

- road Mobile (Non

- road) ; Other

- Area ( Area ) ; and On

- road Mobile (On

- road).

7 "safety margin" means the amount by which the total projected emissions from all sources of a given pollutant are less than the total emissions that would satisfy the applica ble requirement for reasonable further progress, attainment, or maintenance.25

Demonstration

N O
x

Table 1 6

- Butler County , Ohio NO
x Emission Inventory

Totals ( TSD )

Sector 2011

Base 2014

Attainment 2020

Interim 2030

Maintenance Safety

Margin

EGU 1.12 0.96 0.22 0.26

Non

- EGU 9.55 11.74 9.55 9.57

Air 0.02 0.02 0.02 0.00

Non

- road 4.27 3.39 2.03 1.16

Area 4.78 4.78 4.78 4.79

On

- road 12.24 8.85 4.74 2.44

TOTAL 31.98 29.74 21.34 18.22 11.52

Table 17

- Clermont County, Ohio NO
x Emission Inventory Totals

(TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 30

Maintenance Safety

Margin

EGU 43.41 41.17 31.18 31.18

Non

- EGU 0.14 0.03 0.14 0. 14

Air 0.00 0.00 0.00 0. 00

Non

- road 2.27 1.81 1.11 0.63

Area 1.14 1.14 1.14 1.15

On

- r oad 7.52 5.44 2.91 1.50

TOTAL 54.48 49.59 36.48 34.60 14.99

Table 18

- Clinton County, Ohio N Ox Emission Inventory

Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 30

Maintenance Safety

Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.00 0.00 0.00 0.00

Air 0.00 0.00 0.00 0.00

Non

- road 1.15 0.96 0.64 0.29

Area 0.52 0.52 0.52 0.53

On

- road 4.53 3.51 1.86 1.28

TOTAL 6.20 4.99 3.02 2.10 2.8926

T able 19

- Hamilton County, Ohio NO
x Emission Inventory

Totals (TSD)

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 17.72 17.46 10.15 10.15

Non

- EGU 8.57 4.19 8.58 8.60

Air 0.02 0.02 0.02 0.00

Non

- road 8.56 6.76 4.06 2.59

Area 10.09 10.08 10.08 10.1 0

On

- r oad 33.69 24.37 13.05 6.71

TOTAL 78.65 62.88 45.94 38.15 24.73

Table 20

- Warren County, Ohio NO
x Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EG U 0.00 0.00 0.00 0.00

Non

- EGU 1.55 0.96 1.54 1.54

Air 0.00 0.00 0.00 0.00

Non

- road 3.24 2.55 1.50 0.78

Area 1.66 1.66 1.66 1.67

On

- road 9.84 7.12 3.81 1.96

TOTAL 16. 29 12.29 8.51 5.95 6.34

Table 2 1

- Dearborn County , Indiana NO
x Emission Inventory

( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 15.08 10.60 0.26 0.26

Non

- EGU 2.71 1.14 2.70 2.70

Air 0.00 0.00 0.00 0. 00

Non

- road 0.53 0.44 0.30 0.18

Area 0.47 0.47 0.48 0.48

On

- road 1. 03 0.74 0. 40 0. 21

TOTAL 19.82 13. 39 4. 14 3.83 9. 5627

Table 2 2

- Boone County , Kentucky NO
x Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU/ Non

EGU 7.19 7.37 7.86 8.51

Air 2.03 2.07 2.29 0.29

Non

- road 1.06 0.88 0.60 0.38

Area 0.43 0.43 0.43 0.44

On

- road 6.90 5.46 2.41 1.05

TOTAL 17.61 16.21 13.59 10.67 5.54

Table 2 3

- Campbell County , Kentuck y NO
x Emission Inventory

Total ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU/ Non

EGU 0.17 0.17 0.17 0.17

Air 0.00 0.00 0.00 0.00

Non

- road 0.38 0.32 0.23 0.15

Area 0.49 0.49 0.49 0.49

On

- road 4.30 3.41 1 .50 0.65

TOTAL 5.34 4.39 2.39 1.46 2.93

Table 2 4

- Kenton County , Kentucky NO
x Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU/ Non

EGU 0.01 0.01 0.01 0.01

Air 0.00 0.00 0.00 0.00

Non

- road 0.77 0.64 0.43 0.27

Area 1.02 1.02 1.02 1.02

On

- road 6.53 5.17 2.28 0.99

TOTAL 8.33 6.84 3.74 2.29 4.5528

Table 2 5

- Cincinnati

- OH

- KY

- IN A rea NO
x Emission Inventory

Totals ( TSD )

NOx 20 11 Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

Butler 31.98 29.74 21.34 18.22

Clermont 54.48 49.59 36.48 34.60

Clinton 6.20 4.99 3.02 2.10

Hamilton 78.65 62.88 45.94 38.15

Warren 16.29 12.29 8.51 5.95

Dearborn 19.82 13. 39 4. 14 3.83

Boone 17.61 1 6.21 13.59 10.67
Campbell 5.34 4.39 2.39 1.46

Kenton 8.33 6.84 3.74 2.29

COMBINED

NOx

TOTAL 23 8.70 200. 32 13 9.15 117. 27 83. 0529

VOC

Table 2 6

- Butler County , Ohio VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Int erim 20 3 0

Maintenance Safety

Margin

EGU 0.03 0.02 0.02 0.02

Non

- EGU 3.06 2.94 2.96 2.98

Air 0.03 0.03 0.03 0.01

Non

- road 2.93 2.61 2.23 2.43

Area 9.59 9.51 9.38 9.31

On

- road 10.21 7.59 4.79 2.88

TOTAL 25.85 22.70 19.41 17.63 5.07

Table 2 7

- Clermont County , Ohio VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.28 0.22 0.31 0.43

Non

- EGU 0.21 0.41 0.20 0.21

Air 0.01 0.01 0.01 0.00

Non

- road 1.95 1.73 1.43 1.46

Area 5.41 5.36 5.28 5.20

On

- road 6.27 4.66 2.94 1.77

TOTAL 14.13 12.39 10.17 9.07 3.32

Table 2 8

- Clinton County , Ohio VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20 Interim 20 3 0

Maintenance Safety

Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.00 0.01 0.00 0.01

Air 0.01 0.01 0.01 0.00

Non

- road 0.84 0.71 0.51 0.42

Area 2.49 2.51 2.54 2.61

On

- road 2.27 1.53 0.93 0.71

TOTAL 5.61 4.77 3.99 3.75 1.0230

Table 2 9

- Hamilton County , Ohio VOC Emission Inventory

T otals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.26 0.28 0.19 0.24

Non

- EGU 2.36 2.45 2.35 2.38

Air 0.04 0.04 0.04 0.00

Non

- road 7.44 6.54 5.42 5.87

Area 21.88 21.66 21.30 21.01

On

- road 28.09 2 0.88 13.18 7.92

TOTAL 60.07 51.85 42.48 37.42 14.43

Table 30

- Warren County , Ohio VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.00 0.00 0.00 0.00

Non

- EGU 0.62 0.51 0.60 0. 58

Air 0.01 0.01 0.01 0.00

Non

- road 2.12 1.93 1.54 1.51

Area 5.71 5.66 5.59 5.52

On

- road 8.21 6.10 3.85 2.32

TOTAL 16.67 14.21 11.59 9.93 4.28

Table 3 1

- Dearborn County , Indiana VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

A ttainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU 0.27 0. 17 0.05 0.05

Non

- EGU 4.01 5.37 4.01 4.01

Air 0.00 0.00 0.00 0.00

Non

- road 0.42 0.36 0.29 0.27

Area 1.75 1.75 1.77 1.85

On

- road 0.86 0. 64 0. 40 0. 24

TOTAL 7. 31 8 .29 6. 52 6. 4 2 1.8731

Table 3 2

- Boone County , Kentucky VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU/ Non

- EGU 1.73 1.73 1.73 1.73

Air 0.42 0.42 0.45 0.06

Non

- road 1.49 1.30 1.03 0.92

Are a 2.66 2.56 2.41 2.36

On

- road 3.30 2.53 1.38 0.77

TOTAL 9.60 8.54 7.00 5.84 2.70

Table 3 3

- Campbell County

, Kentucky VOC Emission Inventory

Totals ( TSD )

Sector 20 11

Base 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU/ Non

EGU 0.2 2 0.22 0.22 0.21

Air 0.00 0.00 0.00 0.00

Non

- road 0.40 0.34 0.25 0.22

Area 1.29 1.26 1.22 1.19

On

- road 2.05 1.58 0.86 0.48

TOTAL 3.96 3.40 2.55 2.10 1.30

Table 3 4

- Kenton County , Kentucky VOC Emission Inventory

Totals ( TSD )

Sector 20 11

B ase 20 14

Attainment 20 20

Interim 20 3 0

Maintenance Safety

Margin

EGU/ Non

EGU 0.51 0.51 0.49 0.47

Air 0.00 0.00 0.00 0.00

Non

- road 0.62 0.55 0.47 0.50

Area 2.51 2.43 2.31 2.25

On

- road 3.12 2.39 1.30 0.73

TOTAL 6.76 5.88 4.57 3.95 1.9332

Ta ble 3 5

- Cincinnati

- OH

- KY

- IN Area VOC Emission Inventory

Totals ( TSD )

VOC 20 11 Base 20 14

Attainment 20 20 Interim 20 3 0

Maintenance Safety

Margi

n

Butler 25.85 22.70 19.41 17.63

Clermont 14.13 12.39 10.17 9.07

Clinton 5.61 4.77 3.99 3.75

Hamilton 6 0.07 51.85 42.48 37.42

Warren 16.67 14.21 11.59 9.93

Dearborn 7. 31 8 .29 6. 52 6. 42

Boone 9.60 8.54 7.00 5.84

Campbell 3.96 3.40 2.55 2.10

Kenton 6.76 5.88 4.57 3.95

COMBINED

VOC

TOTAL 1 49.96 13 2.03 108. 28 96. 11 3 5.92

VOC and NOx

Table 3 6

- Cincinnati

- OH

- KY

- IN A rea Comparison of 2014

attainment year and projected emission estimates ( TSD )

20 14 20 20 20 20 Projected

Decrease 20 3 0 20 3 0

Projected

Decrease

VOC 13 2.03 1 08.28 23. 75 96.11 35. 92

NO

x 20 0.32 1 3 9 .15 6 1 .17 1 17.27 83. 05

As shown in the table above, VOC emissions in the

nonattainment ar ea a r e projected to decrease by 23. 75 TSD in

20 20 and 3 5

. 92 TSD in 20 3 0

. In general, emissions for all sectors are projected to decline or remain stable . EGU sources
in Clermont County (OH) show a very slight increase , but this is fractional compared to the overall reductions expected. Furthermore, Butler County (OH) and Warrant County (OH)

show minor increase s in regards to n on

- EGU emissions while

Clinton County (OH) and Dearborn County ( IN) show slight

increase s in area emissions

. A gain these increases do not

affect the overall reduction in VOC emissions for the area and are likely contributed to slight changes in population projections

. C leaner vehicles and fuels are expected to be in p lace in 2018

and will cause an overall drop in VOC emissions.

NO

x emissions in the nonattainment area are projected to33

d ecrease by 6 1 .17 TSD in 20 20 and 83. 05 TSD in 20 3 0

. EGU,

non

- road and on

- road emissions are all projected to decline

while non

- EGU

, AI R and area emissions are projected to remain steady overall or slightly increase

. Clermont County (OH), Warren County (OH), Hamilton County (OH), and Dearborn County (IN) show an increase in non

- EGU emissions is expected due to 2030 projections being based upon 2011 emissions. In reality, emissions dropped more dramatically in 2014 than predicted. Boone County (KY) is estimated to have an increase

in EGU / non

- EGU emissions which is likely contributed to slight changes in population projections. These slig ht increases do not

affect the overall reduction in NOx emissions for the area and are likely contributed to slight changes in population projections.

Decreases from U.S. EPA rules covering EGUs (NOx SIP Call, CAIR and CSAPR), Tier 2 Motor Vehicle Emissio ns Standards and Gasoline Sulfur Control Requirements 8 , Highway Heavy

Duty Engine Rule 9

, and the Non

- Road Diesel Engine Rule 10 are factored into the changes.

As identified in Table 14 and Table 15 above, an additional mobile budget margin of safety allo cation is being requested for

mobile emissions. The mobile budget margin of safety

allocation translates into an additional 4. 4 8 TSD for VOC and

5.22 TSD for NOx in the year 20 20 and 3.22 TSD for VOC and

3.80 TSD for NOx in the year 20 3 0. U.S. EPA’s confo rmity regulations allow for allocation, through a revision to the SIP, of all or some portion of the overall area’s safety margin (emission

reductions from 2014 to 20 3 0 ) to the mobile emissions budgets for future conformity. As identified in Table 14 and Table 15 above, the mobile budget margin of safety allocation and the total budget is distributed separately between Kentucky (alone) and Ohio/Indiana (combined). For the entire area, Ohio , Indiana and Kentucky chose to allocate :

- In 20 20 : 4. 4 8 TSD of the 23. 75 TSD safety margin for

VOC and 5.22 TSD of the 6 1 .17 TSD safety margin for NOx as a mobile emissions budget safety margin.

- In 20 3 0: 3.22 TSD of the 35. 92 TSD safety margin for

VOC and 3.80 TSD of the 8 3. 05 TSD safety margin for

NOx as a mobile emi ssions budget safety margin.

8 http://www.epa.gov/fedrgstr/EPA

- AIR/2000/February/Day

- 10/a19a.htm

9 http://www.epa.gov/fedrgstr /EPA

- AIR/1997/October/Day

- 21/a27494.htm

10 http://www.epa.gov/fedrgstr/EPA

- AIR/1998/October/Day

- 23/a24836.htm34

Requirement 4 of 5 A demonstration that improvement in air quality between the year violations

occurred and the year attainment was achieved is based on permanent and enforceable emission reductions and not on temporary a dverse economic

conditions or unusually favorable meteorology.

Background Ambient air quality data from all monitoring sites indicate that air quality met the NAAQS for ozone in 20 12 through 20 14

. U.S.

EPA ’s R edesignation G uidance (p 9) states : “A state may generally demonstrate maintenance of the NAAQS by either showing that future emissions of a pollutant or its precursors will not exceed the level of the attainment inventory, or by modeling

to show that the future mix of sources and emissions rates wil l
not cause a violation of the NAAQS.”

Demonstration

Permanent and enforceable reductions of VOC and NOx

emissions have contributed to the attainment of the eight

- hour

ozone stan dard. Some of these reductions were due to the application of tighter feder al standards on new vehicles and non

road diesel engines while reductions in EGU emissions were due to implementation of CAIR/CSAPR

.

With respect to EGUs, changes at several facilities have resulted

in reductions in NOx emissions. Tanner’s Creek Generat ing Station in Dearborn County (IN) permanently shutdown in May of 2015. Prior to the shutdown, NOx emissions had dropped from

15.08 TSD to 10.60 TSD (2011 to 2014). The Walter C. Beckjord facility in Clermont County (OH) permanently shutdown

in October of 2014. Prior to the shutdown, NOx emissions had dropped in Clermont County from 43.41 TSD to 41.17 TSD (2011 to 2014), partly attributable to the Walter C. Beckjord facility. And lastly, unit 3 (163 megawatts) of the Miami Fort facility in Hamilton Cou nty (OH) permanently shutdown in June of 2015. Prior to the shutdown, NOx emissions had dropped in Hamilton County from 17.72 TSD to 17.46 TSD (2011 to 2014), partly attributable to unit 3 at Miami Fort.

Reductions achieved are discussed in greater d etail under Chapter Five.35

Table 3 7

- Cincinnati

, OH

- KY

- IN A rea Combined Comparison of

20 11 base y ear and 20 14 attainment year EGU, non

road, and on

- road reductions

20 11 20 14

EGU NOx 84. 70 7 7.74

Non

- road NOx 22.23 17.75

Non

- road VOC 18.21 16.07

O n

- road VOC 64. 38 4 7.90

On

- road NO

x 8 6.58 64. 07

To further support Ohio’s demonstration that the improvement in air quality between the year violations occurred and the year attainment was achieved is based on permanent and

enforceable emission redu ctions and not on temporary adverse

economic conditions or unusually favorable meteorology

, a n analysis was performed by the Lake Michigan Air Directors Consortium (LADCO) in order to demonstrate the improvement in air quality is not based on unusually fav orable meteorology. Appendix D includes additional details and methodology regarding this analysis.

A classification and regression tree analysis was conducted with

the 2000 through 2014 data from three Cincinnati area ozone sites: Colerain (EPA site numb er 3906100101), Sycamore (3906100061), and Taft (390610040). The goal of the analysis was to determine the meteorological and air quality conditions associated with ozone episodes, and construct trends for the days identified as sharing similar meteorolog ical characteristics. Regression trees were developed for the three Cincinnati monitors to classify each summer day (May

- September) by its ozone concentration and associated meteorological conditions. Similar days are assigned to nodes, which are equivale nt to branches of the regression tree. Ozone trends in these nodes are then plotted (see Figure 2 )

.36

Figure 2

- Trends in High

- Ozone Nodes for Cincinnati Monitors

By grouping days with similar meteorology, the influence of meteorological variabilit y on the underlying trend in ozone concentrations is partially removed; the remaining trend is presumed to be due to trends in precursor emissions or other

non

- meteorological influences. Trends in Cincinnati are declining over the period examined. No a p riori selection of important meteorological variables is used to develop the trees; instead, the CART model searches exhaustively through the 60 meteorological variables supplied to determine which are most efficient in predicting ozone. Although the exac t selection of predictive variables changes from site to site, the universally common predictors are temperature, wind direction, and relative humidity. These are included in the dataset as daily averages and maximums as well as averages at specific times throughout the day (morning 7

- 10 am, afternoon 1

- 4 pm, etc.).

Meteorological data are from National Weather Service monitoring stations, usually airports. Upper air data are included as well. Because the upper air sites are far fewer in number

than surface observation sites, data from the nearest upper air site is matched to each surface site. Hourly meteorological37

parameters used in the models included temperature, wind speed, wind direction, solar radiation, relative humidity, dew point, precipita tion, fog, cloud attenuation, and station pressure. Daily meteorological parameters included the morning mixing height, winds and temperature at 925, 850, and 700 mb, transport distance (24

- hr trajectory length), and transport

direction.

Both classifica tion trees and regression trees were examined, and performed quite similarly. Regression trees were preferred in this analysis because the trees yield quantitative values for predicted ozone rather than a simple episode/nonepisode indicator. Ranks of pr edictor variables were similar for both types of models. Models were tested with 10

- fold cross

validation. Figure 3 shows a portion of the regression tree for

Cincinnati.38

Figure 3

- Partial Regression tree for Cincinnati (highlighted

boxes are high

- c oncentration nodes 10 and 12 used for trends)

The analysis above further supports Ohio’s demonstration that

the improvement in air quality between the year violations

occurred and the year attainment was achieved is based on permanent and enforceable e mission reductions and not on unusually favorable meteorology

.

Requirement 5 of 5 Provisions for future annual updates of the inventory to enable tracking of the

emission levels

, including an annual emission statement from major sources.

Demonstrati on In Ohio, major point sources in all counties are required to

submit air emissions information annually, in accordance with U.S. EPA’s Consolidated Emissions Reporting Rule (CERR). Ohio EPA prepares a new periodic inventory for all ozone precursor emiss ion sectors every three years. These ozone precursor inventories will be prepared for future years as necessary to comply with the inventory reporting req uirements

established in the CFR

. Emissions information will be compared39

to the 20 11 base year and t he 20 3 0 projected maintenance year inventories to assess emission trends, as necessary, and to assure continued compliance with the ozone standard.40



### CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS

CAA Section 107 ( d)(3)(E)(ii), 107(d)(3)(iv) & 107(d)(3)(E)(v )

Requirement 1 of 4 Section 182(a)(3)(B) requires states to submit emissions statements.

Background Section 182(a)(3)(B) requires states to submit emissions statements within two years of the enactment of the Clean Air Act Amendments and then every th ree years thereafter.

Demonstration Ohio EPA submitted its emissions statement SIP on March 18, 1994 which was approved by U.S. EPA on October 13, 1995 (59 FR 51863). In addition, on July 18, 2014, Ohio EPA submitted a

SIP revision for this area and U. S. EPA published a proposal

and direct final action approving that submittal on March 10, 2016 ( 81 FR 12626 and 81 FR 12591). The approval will be effective May 9, 2016, unless U.S. EPA receives adverse comments by April 11, 2016

. As discussed in Chapter Four ( Requirement 4), Ohio EPA submits, and commits to submit, emission inventories (statements) every three years.

Requirement 2 of 4 Evidence that control measures required in pas t ozone SIP revisions have been fully implemented.

Background

O n Octob er 27, 1998, U.S. EPA promulgated the NO

x S IP Call requiring 22 states to pass rules that would result in significant emission reductions from large EGUs, industrial boilers, and

cement kilns in the eastern United States. Ohio promulgated this

rule in 2001

. NOx SIP Call requirements are incorporated into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations discovered by field office staff. Compliance is tracked through the Clean Air Markets data monitoring program. Be ginning in 2004, this

rule account s for a reduction of approx imately 31 percent of all

NO

x emissions state wide compared to previous uncontrolled

years. The other 21 states als o have adopted these rules.

As discussed in detail below, U.S. EPA subsequently replaced

the NOx SIP Call with CAIR and CSAPR. CSAPR continue s to41

be implemented and amounts to even further reductions than

that realized under the NOx SIP Call.

Section 182(b) contains additional provisions applicable to moderate nonattainment areas, for which the Cincinnati

, OH

- KY

IN area was under the one

- hour standard. Section 182(b)(3) requires gasoline vapor recovery systems for gasoline dispensing stations in the ar ea

, and Section 182(b)(4) requires motor vehicle inspection and maintenance programs , and Section 182(b)(2) requires RACT under Section 172(c)(1)

.

D emonstration

NOx SIP Call

Controls for EGUs under the NOx SIP Call formally commenced May 31, 2004. E mi ssions covered by this program have been generally trending downward since 1998 with larger reductions occurring in 2002 and 2003. D ata taken from the U.S. EPA

Clean Air Markets w eb site, quantif y the gradual NO

x reductions

that have occurred in Ohio as a result of Title IV of the 1990

CAA Amendments and the beginning of the NO

x SIP Call Rule. Ohio developed the NO

x Budget Trading Program rules in OAC Chapter 3745

- 14 11 in response to the SIP Call. OAC Chapter

3745

- 14 regulates EGUs and certain non

- EGUs und er a cap and trade program based on an 85 percent reduction of NOx emissions from EGUs and a 60 percent reduction of NO

x emissions from non

- EGUs, compared to historical levels. This

cap stayed in place through 2008, at which time the CAIR program supersed e d it as discussed above

.

On April 21, 2004, U.S. EPA published Phase II of the NO x SIP Call that establishes a budget for large (greater than 1 ton per day emissions) stationary internal combustion engines. Ohio

EPA’s OAC rule 3745

- 14

- 12 addresses stat ionary internal combustion engines, all used in natural gas pipeline transmissions. U.S. EPA approved this revision to the SIP on April 4, 2008. An 82 percent NO x reduction from 1995 levels is anticipated. Completion of the compliance plan occurred by May
1, 2006

, and the compliance demonstration began May 1, 2007.

The 2007 controlled NO x emissions are 599 tons statewide for

the ozone season

.

As discussed further below, s tarting January 1, 2009, CAIR

commenced and emissions covered by this program have

11 http://www.epa.state.oh.us/dapc/regs/3745

- 14/3745_14.html42

con tinued trending downward. D ata taken from the U.S. EPA

Clean Air Markets w eb site, quantif y the gradual NO

x reductions

that have occurred in Ohio as a result of implementation of CAIR. CAIR’s cap and trade program stayed in place through
2014, at which ti me the CSAPR program superseded it.

The following graph depicts the trend in NOx emissions from

EGUs for the entire nonattainment area:

Figure 4

- NO
x Emissions from EGUs

– Entire Nonattainment Area

Electric Generating Units,

2003

- 201443

VOC RACT

The Cincinnati area was required to adopt RACT for the following source categories under Section 182(b)(2) for the one

hour standard : (a) all VOC sources covered by Control Technique Guidelines (C TGs) issued between November 15,

1990 and the date the Cincinnati area attained the one

- hour ozone standard; (b) all VOC sources covered by a CTG issued prior to November 15, 1990; and (c) all other major non

- CTG stationary sources in the Cincinnati area.

U.S. EPA approved Ohio EPA’s V OC RACT r ules on September 7, 1994 (59 FR 46182 ) , October 23, 1995 (60 FR 54308), April 25, 1996 (61 FR 18255) , and June 21 , 2005 (70 FR 35946 )

.

RACT rules have been applied to all new sources locating in

Ohio since that time. RACT requirements are incorporate d into permits along with monitoring, recordkeeping, and reporting necessary to ensure ongoing compliance. Ohio EPA also has an active enforcement program to address violations discovered by field office staff. The Ohio RACT rules are found in OAC Chapte r 3745

- 21 12

.

Gasoline Vapor Recovery Systems

Section 182(b)(3) requires states to submit Stage II vapor recovery rules no later than November 15, 1992. The U.S. EPA partially approved and partially disapproved Ohio's SIP revision for implementation of St age II on October, 20, 1994 (59 FR 52911). As stated in that rulemaking action, with the exception of paragraph 3745

- 21

- 09 (DDD)(5), U.S. EPA considers Ohio's Stage II program to fully satisfy the criteria set forth in the September 17, 1993, U.S. EPA guid ance document for such programs entitled "Enforcement Guidance for Stage II Vehicle Refueling Control Programs." Furthermore, the September 17, 1993, guidance memorandum states that once onboard vapor recovery regulations are promulgated, the Stage II regu lations are no longer applicable for moderate ozone nonattainment areas. The U.S. EPA promulgated onboard vapor recovery rules in February 1994. Therefore, pursuant to Section 202(a)(6) of the CAA, Stage II would no longer be required. However, some

area s, including Ohio, retained Stage II requirements to provide a control method to comply with rate

- of

- progress emission reduction targets. Congress recognized that onboard refueling vapor recovery and Stage II would eventually become

12 http://www.epa.state.oh.us/dapc/regs/3745

- 21/3745_21.html44

redundant , and actually increase emissions, and provided the U.S. EPA authority to allow states to remove Stage II from their SIPs after U.S. EPA finds that onboard refueling vapor recovery is in widespread use. On May 16, 2012, the U.S. EPA determined that onboard refueling vap or recovery technology is in widespread use throughout the motor vehicle fleet for purposes of controlling motor vehicle refueling emissions. This action (77 FR 28772) also provided notice of an upcoming guidance document for states to use to prepare a SI P revision to remove or phase

- out Stage II controls. U.S. EPA published this guidance on August 7, 2012 (EPA

- 457/B

- 12

- 001). The guidance noted that since Section 182(b)(3) requirements no longer applied, the only requirements for Stage II controls are

st ate SIPs (which includes Ohio, as noted above ) , Section 184(b)(2) for areas in the ozone transport region (does not apply to Ohio)

, and section 193 for any area that adopted Stage II controls prior to November 15, 1990 (does not apply to Ohio). In

order t o remove Stage II control requirements from the SIP, CAA Section 110(l) is required to be addressed. Ohio EPA

conducted this demonstration a nd submitted the SIP revision request to U.S. EPA on July 15, 2015

. This demonstration included a new requirement for the use of low permeation hoses which will provide even greater VOC emissions reductions in the

future.

Motor Vehicle Inspection and Maintenance Program

The U.S. EPA's final I/M regulations in 40 CFR Part 85 require the states to submit a fully ado pted I/M program by November
15, 1993 under Section 182(b)(4) . U.S. EPA approved Ohio's enhanced I/M program (E

- Check), on April 4, 1995 (60 FR 16989) and January 6, 1997 (62 FR 646). The E

- C heck

program is no longer being implemented in this area. On

No vember 3, 2005 , Ohio EPA submitted a request for replacement of the E

- Check program in this area . In order to

transfer the E

- Check program from the active maintenance plan to a contingency plan, alternative emission reduction programs were adopted to repl ace the benefits associated with the E

Check program in the one

- hour maintenance plan approved at

that time. The following programs were implemented in place of

the E

- Check program and are still being implemented today in the original one

- hour attainment a rea (excludes Clinton County):

 OAC rule 3745

- 21

- 09(O)(2)(e)

- Vapor pressure limit for cold cleaning degreasing operations. Approved July 28,

2009 ( 74 FR 37171 )45  OAC rule 3745

- 21

- 18

- Mobile equipment refinishing emission reduction via high transfer effic iency spray guns. Approved July 28, 2009 ( 74 FR 37171 )

 OAC Chapter 3745

- 72

- Low Reid Vapor Pressure Fuels

. Approved May 25, 2007 (72 FR 29269 )

 OAC rule 3745

- 21

- 17

- Portable Fuel Containers

. Approved October 14, 2009 (74 FR 52691 )

In addition to the abo ve, there are several measures beyond the CAA requirements that have been implemented in this area.

Tier II Emission Standards for Vehicles and Gasoline Sulfur

Standards

In February 2000

, U.S. EPA finalized a federal rule to significantly reduce emission s from cars and light trucks, including sport utility vehicles (SUVs). Under this proposal, automakers will be required to sell cleaner cars, and refineries will be required to make cleaner, lower sulfur gasoline. This rule will apply nationwide. The f ederal rules w ere phase d in

between 2004 and 2009. U.S. EPA has estimated that NO

x emission reductions were approxima tely 77 percent for

passenge r cars, 86 percent for smaller SUVs, light truc ks, and minivans, and 65 to 95 percent reductions for larger SU Vs, vans,

and heavier trucks. VOC emission reductions were

ap proximately 12 percent for passen ger cars, 18 percent for smaller SUVs, light trucks, and min ivans, and 15 percent for larger SUVs, vans, and heavier trucks.

Tier III Emission Standards for V ehicles and Gasoline Sulfur

Standards

In March 2014, U.S. EPA finalized a federal rule to further strengthen Tier II vehicle emission and fuel standards. This rule will require automakers to produce cleaner vehicles and

refineries to make cleaner, lower s ulfur gasoline. This rule will be phased in between 2017 and 2025. Tier III requires all passenger vehicles to meet an average standard of 0.03 gram/mile of NOx. Compared to Tier II, the Tier III tailpipe standards for light

- duty vehicles are expected to reduce NOx and VOC emissions by approximately 80%. Tier III vehicle

standards also include evaporative standards using onboard diagnostics that will result in a 50% reduction in VOC emissions compared to Tier II reductions. The rule reduces the sulfur

cont ent of gasoline to 10 ppm, beginning in January 2017.46

Heavy

- Duty Diesel Engines

In July 2000, U.S. EPA issued a final rule for Highway Heavy Duty Engines, a program which includes low

- sulfur diesel fuel
standards, which was phased in from 2004 through 2 007. This rule applies to heavy

- duty gasoline and diesel trucks and buses.

This rule resulted in a 40 percent reduction in NO

x from diesel trucks and buses, a large sector of the mobile sources NO

x inventory.

Clean Air Non

- road Diesel Rule

In May 2004, U.S. EPA issued the Clean Air Non

- road Diesel Rule. This rule applies to diesel engines used in industries such as construction, agriculture, and mining. It also contains a cleaner fuel standard similar to the highway diesel program. The

new standards c ut emissions from non

- road diesel engi nes by more than 90 percent . Non

- road diesel equipment, as described in this rule, accounted for 47 percent of diesel particulate matter (PM) and 25 percent of NO

x from mobile sources nationwide.

Sulfur levels were r educed in non

- road diesel fuel by 99 percent

from previous levels, from appr oximately 3,000 parts per million (ppm ) to 15 ppm in 2009. New engine standards took effect, based on engine horsepower, starting in 2008.

Non

- road Spark

- Ignition Engines and Rec reational Engine

Standards

Effective in January 2003, this standard regulates NOx, VOCs, and carbon monoxide (CO) for groups of previously unregulated

non

- road engines. This standard applies to all new engines sold in the United States and imported after the standards went into effect. The standard applies to large spark

- ignition engines (forklifts and airport ground service equipment), recreational vehicles (off

- highway motorcycles and all

- terrain vehicles), and recreational marine diesel engines. When al l of the non

- road spark

- ignition engines and recreational engine standards are fully implemented, an overall 80% reduction in NOx, 72% reduction in VOC, and 56% reduction in CO emissions are expected by 2020.

Reciprocating Internal Combustion Engine Stand ards

This new standard, effective in May 2010, regulates emissions of air toxics from existing diesel powered stationary reciprocating internal combustion engines that meet specific site rating, age, and size criteria. These engines are typically used at industrial47

facilities (e.g. power, chemical, and manufacturing plants) to generate electricity for compressors and pumps and to produce electricity to pump water for flood and fire control during emergencies.

The standard applies to stationary diesel engi nes: (1) that are located at a major source of air toxics emissions and that were installed prior to June 12, 2006; (2) used at major sources of air toxics, having a site rating of less than or equal to 500 horsepower and were constructed or reconstructed before June 12, 2006; and (3) used at major sources of air toxics for nonemergency purposes, having a site rating of greater than 500 horsepower and were constructed or reconstructed before
December 19, 2002.

Operators of existing engines were required to : (1) install emission control equipment that would limit air toxics up to 70% for stationary non

- emergency engines with a site rating greater than 300 horsepower; (2) perform emission tests to demonstrate engine performance and compliance with rule requir ements; and (3) burn ultra

- low sulfur fuel in stationary non

- emergency engines with a site rating greater than 300 horsepower.

The engine standards took effect in 2013. According to U.S.
EPA estimates, this rule has resulted in emission reductions

from e xisting diesel

- powered stationary reciprocating internal combustion engines of approximately 1,000, 2,800, and 27,000 tpy of air toxics, fine particles (PM2.5), and CO, respectively.

Category 3 Marine Diesel Engine Standards

This new standard, effective in June 2010, promulgated more stringent exhaust emission standards for new large marine diesel engines with per

- cylinder displacement at or above 30 liters (commonly referred to as Category 3 compression

- ignition marine engines) as part of a coordinated s trategy to address emissions from all ships that affect U.S. air quality. These emission standards are equivalent to those adopted in the

amendments to Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL Annex VI). T he emission standards apply in two stages: near

- term standards, for newly built engines, which took effect in 2011 and long

- term standards requiring an 80% reduction in NOx emissions that will begin in 2016.

U.S. EPA is adopting changes to the diesel fuel program to allow for the production and sale of diesel fuel with up to 1,000 ppm48

sulfur for use in Category 3 marine vessels. The regulations generally forbid production and sale of fuels with more than 1,000 ppm sulfur for use in most U.S. waters unless operators achieve equivalent emission reductions in other ways. U.S. EPA is also adopting provisions to apply some emission and fuel standards to foreign flagged and in

- use vessels that are covered by MARPOL Annex VI. When this strategy is fully implemente d in 2030, U.S. EPA estimates that NOx and PM2.5 emissions in the U.S. will be reduced by approximately 1.2 million tpy and 143,000 tpy, respectively.

Clean Air Interstate Rule (CAIR)/Cross State Air Pollution Rule (CSAPR)

On May 12, 2005, U.S. EPA publi shed the following regulation:

“Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (CAIR); Revisions to Acid Rain Program; Revisions to the NOx SIP Call; Final Rule.” This rule established the requirement for states to adopt rules lim iting the emissions of NOx and SO2 and provided a model rule for the states to use in developing their rules in order to meet federal requirements. The purpose of CAIR was to reduce interstate transport of PM2.5, SO2, and ozone precursors (NOx).

CAIR appl ied to any stationary, fossil fuel

- fired boiler or stationary, fossil fuel

- fired combustion turbine, or a generator with a nameplate capacity of more than 25 megawatt electrical (MWe) producing electricity for sale. This rule provided annual state caps for NOx and SO2 in two phases, with Phase I caps for NOx and SO2 taking effect in 2009 and 2010, respectively.

Phase II caps were to become effective in 2015. U.S. EPA allowed limits to be met through a cap and trade program if a state chose to participate in the program. SO2 emissions from power plants in the 28 eastern states, as well as Washington D.C subject to CAIR were to be cut by 4.3 million tons from 2003 levels by 2010 and 5.4 million tons from 2003 levels by 2015.

NOx emissions were to be cut by 1.7 million tons by 2009 and reduced by an additional 1.3 million tons by 2015. In response to U.S. EPA’s rulemaking, Ohio submitted a CAIR SIP which was approved by U.S. EPA on February 1, 2007. Revisions to the CAIR SIP were again submitted on July 15, 2009 . The revised CAIR SIP was approved as a direct final action on September 25, 2009 (74 FR 48857). Ohio’ s rule included annual and seasonal NOx trading programs, and an annual SO2 trading program. This rule required compliance effective January 1,

2009.49

In July 2008, the D.C. Circuit court vacated CAIR and issued a subsequent remand without vacatur of CAIR in December 2008. The court then directed U.S. EPA to revise or replace CAIR in order to address the deficiencies identified by the court. On July
6, 2 011, U.S. EPA finalized CSAPR as a replacement for CAIR. On August 21, 2012, the U.S. Court of Appeals for the D.C.

Circuit vacated CSAPR and directed U.S. EPA to continue administering CAIR “pending the promulgation of a valid replacement.” In a subsequen t decision on the merits, the Court vacated CSAPR based on a subset of petitioners’ claims, but on April 29, 2014, the U.S. Supreme Court reversed that decision

and remanded the case to the D.C. Circuit court for further proceedings. Throughout the initial round of D.C. Circuit proceedings and the ensuing U.S. Supreme Court proceedings, the stay remained in place and U.S. EPA has continued to implement CAIR. In order to allow CSAPR to replace CAIR in an equitable and orderly manner while further D.C. Circui t Court proceedings were held to resolve petitioner’s remaining claims, U.S. EPA filed a motion asking the D.C. Circuit Court to lift the stay. U.S EPA also asked the court to toll all CSAPR compliance deadlines that had not passed as of the date of the st ay order by three years. On October 23, 2014, the Court granted the U.S.

EPA’s motion. CSAPR became effective on January 1, 2015, for SO2 and annual NOx, and May 1, 2015 for ozone season NOx. Combined with other final state and U.S. EPA actions, CSAPR

will reduce power plant SO2 emissions by 73% and NOx emissions by 54% from 2005 levels in the CSAPR region, which includes the states of Indiana, Kentucky, and Ohio.

Oil and Natural Gas Industry Standards

This new standard, issued on April 17, 2012, regulate s VOC and

air toxic emissions from hydraulically fractured natural gas wells and also includes requirements for several other sources of pollution in the oil and natural gas industry that were previously unregulated in the United States. U.S. EPA estimates that these standards will apply to approximately 11,400 new natural gas wells hydraulically fractured each year and an additional 1,400 existing natural gas wells refractured annually. When these standards are fully implemented in 2015, U.S. EPA estimates that VOC and air toxic emissions in the U.S. will be reduced by approximately 190,000 to 290,000 tpy and 12,000 to 20,000 tpy, respectively.50

Mercury and Air Toxic Standards

This new standard, effective in April 2012, regulates emissions of mercury, a cid gases, and non

- mercury metallic toxic pollutants from new and existing coal and oil

- fired EGUs. U.S.

EPA estimates that this rule will apply to approximately 1,100

coal

- fired and 300 oil

- fired EGUs at 600 power plants in the U.S. According to U.S. EPA, most facilities will comply with these standards through a range of strategies, including the use of existing emission controls, upgrades to existing emission controls, installation of new pollution controls, and fuel switching.

Following promulgation of the rule, U.S. EPA received petitions

for reconsideration of various provisions of the rule, including requests to reconsider the work practice standards applicable during startup periods and shutdown periods. U.S. EPA granted

reconsideration of the start up and shutdown provisions as no opportunity to comment was provided to the public regarding the work practice requirements contained in the final rule. On November 30, 2012, U.S. EPA published a proposed rule reconsidering certain new source standards and startup and shutdown provisions in MATS. U.S. EPA proposed certain minor changes to the startup and shutdown provisions contained in the

2012 final rule based on information obtained in the petitions for reconsideration. On April 24, 2013, U.S. EPA took f inal action on

the new source standards that were reconsidered and also the

technical corrections contained in the November 30, 2012, proposed action. U.S. EPA did not take final action on the startup and shutdown provisions and, on June 25, 2013, added

ne w information and analysis to the docket and reopened the public comment period for the proposed revisions. U.S. EPA

took final action on the remaining topics open for reconsideration on November 19, 2014. The compliance date for existing sources was April 16, 2015, while the compliance date for new

sources was April 16, 2012.

On November 25, 2014, the U.S. Supreme Court accepted several challenges to the rules brought by the utility industry and a coalition of nearly two dozen states. On June 29, 2015, th e U.S. Supreme Court ruled that U.S. EPA did not properly account for compliance costs when crafting the MATS rule and

remanded the decision to the D.C. Circuit Court for

reconsideration.

Controls Specific to Ohio Counties51

As discussed above, several fe derally enforceable changes at

EGUs have resulted in reductions in NOx emissions. Tanner’s Creek Generating Station in Dearborn County (IN) permanently shutdown in May of 2015. The Walter C. Beckjord facility in Clermont County (OH) permanently shutdown i n October of 2014. And lastly, unit 3 (163 megawatts) of the Miami Fort facility in Hamilton County (OH) permanently shutdown in June

of 2015.

Together, these rules will substantially reduce local and regiona l sources of

ozone precursors.

Requirement 3 of 4 Acceptable provisions to provide for new source review.

Background Ohio has a longstanding and fully implemented New Source Review (NSR) program. Thi s is addressed in OAC Chapter

3745

- 31 13 . The C hapter includes provisions for the Prevention

of S ignificant Deterioration (PSD) permitting program in OAC

rules 3745

- 31

- 01 to 3745

- 31

- 20. Ohio's PSD program was

conditi onally approved on October 10, 2001 (66 FR 51570 ) and

received final approval on January 22, 2003 (68FR 2909 ) by

U.S. EPA as part of the SIP

.

Demonstration Any facility that is not listed in the 20 08 14 emission inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, reopen, modify, or reconstruct without meeting all applicabl e NSR requirement s

. On ce the area is redesignated, Ohio EPA will implement NSR through the PSD program

.

Requirement 4 of 4

Assure that all existing control measures will remain in effect after redesignation unless the State demonstrates through photoch emical modeling that the standard can be maintained without one (1) or more control measure s.

Demonstration Ohio commits to maintaining the aforementioned control measures after redesignation. Ohio hereby commits that any

13 http://www.epa.state.oh.us/dapc/regs/3745

- 31/3745_31.html 14 On July 18, 2014, Ohio EPA submitted its 2008 base year inventory as requi red under CAA
Section 182(a)(1)52

changes to its rules or emission limits applicable to VOC and/or

NO

x sources, as required for maintenance of the ozone standard

in the Cincinnati area , will be submitted to U.S. EPA for approval

as a SIP revision.

Ohio, through Ohio EPA’s Legal section and the Ohio Attorney

General’s O ffice , has the legal authority and necessary resources to actively enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the emission of ozone precursors in the

Cincinnati a rea.53



### CHAPTER SIX

CONTINGENCY MEASURES

CAA Section 107(d)(3)(E)(v)

Requirement 1 of 4 A commitment to submit a revised plan eight (8) years after redesignation.

Demonstration

Ohio hereby commits to review its maintenance p lan eight (8) years after redes ignation, as required by Section 175(A) of the

CAA

.

Requirement 2 of 4 A commitment to expeditiously enact and implement additional contingency control measures in response to exceeding specified predetermined levels (triggers) or in the event that future vio lations of the ambient standard occur.

Demonstration Ohio hereby commits to adopt and expeditiously implement necessary corrective actions in the following circumstances:

Warning Level Response:

A warning level r esponse shall be prompted whenever a n annual (1

- year) fourth high monitored value of 79 ppb occurs in a single

ozone season within the maintenance area. A warning level

r esponse will consist of a study to determine whether the ozone value indicates a trend toward higher ozone values or wheth er emissions appear to be increasing. The study will evaluate whether the trend, if any, is likely to continue and, if so, the control measures necessary to reverse the trend taking into consideration ease and timing for implementation as well as

economic and social considerations. Implementation of

neces sary controls in response to a warning level r esponse trigger will take place as expeditiously as possible, but in no

event later than 12 months from the conclusion of the most recent ozone season ( October 3 1 ).

Shoul d it be determined through the warning l evel study that action is necessary to reverse the noted trend, the procedures

for control selection and implementation outlined under “ action

l evel response ” shall be followed.54

Action Level Respon se :

An a ction l evel r esponse shall be prompted whenever a two

- year average fourth high monitored value of 76 ppb or greater occurs within the maintenance area. A violation of the standard (three

year average fourth high value of 85 ppb or greater) shall also prompt an action level response. In the event that the a ction

l evel is triggered and is not found to be due to an exceptional event, malfunction, or noncompliance with a permit condition or rule requirement, Ohio EPA in conjunction with the metropoli tan planning organization or regional council of governments, will

determine additional control measures needed to assure future

attainment of the NAAQS for ozone. In this case, measures that can be implemented in a short time will be selected in order to be in place within 18 months from the close of the ozone season that prompted the a ction l evel. Ohio EPA will also consider the timing of an a ction l evel t rigger and determine if additional, significant new regulations not currently included as part of t he maintenance provisions will be implemented in a timely manner and will constitute our response

.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the necessary administrative and legal process. Thi s process will include publication of notices, an opportunity for public hearing, and other measures required by Ohio law for rulemaking.

If a new measure/control is already promulgated and scheduled to be implemented at the federal or S tate level, and t hat

measure/control is determined to be sufficient to address the upward trend in air quality, additional local measures may be unnecessary. Furthermore, Ohio will submit to U.S. EPA an analysis to demonstrate the proposed measures are adequate to

return the area to attainment.

Requirement 3 of 4 A list of potential contingency measures that would be implemented in such an

event.

Demonstration Contingency measures to be considered will be selected from a comprehensive list of measures deemed appropriat e and

effective at the time the selection is made. The select ion of

measures will be based on cost

- effectiveness, emission reduction potential, economic and social considerations or other

factors t hat Ohio EPA deems appropriate. Ohio EPA will solicit55

inp ut from all interested and affected persons in the maintenance area prior to selecting app ropriate contingency

measures. Because it is not possible at this time to determine

what control measure s will be appropriate at an unspecified time in the future, t he list of contingency measures outlined below is

not exhaustive

.

1) Implementation of an enhanced I/M program (E

- Check) in Butler, Clermont, Hamilton and Warren Counties.

2) Tighten or a dopt VOC RACT on existing sources covered by U.S. EPA Control Technique Guidelines issued after

the 1990 CAA

.

3) Apply VOC RA CT to smaller existing sources.

4) One or more transportation control measures sufficient to

achieve at le ast half a percent reduction in actual area wide VOC emissions. Transportation measures will be

sel ected from the following, based upon the factors listed above after consultation with affected local governments:

a) t rip reduction programs, including, but not limited to, employer

- based transportation management plans, area wide rideshare programs, work

sc he dule changes, and telecommuting ;

b) t raffic flow and t ransit improvements ; and

c) o ther new or innovative transportation measures not yet in widespread use that affect ed local governments deem appropriate.

5) Alternative fuel and diesel retrofit programs for f leet vehicle operations.

6) Require VOC or NO

x emission offsets for new and modified major sources.

7) Increase the ratio of emission offsets required for new

sources.

8) Require VOC or NO

x controls on new minor sources (less than 100 tons).

9) Adopt NOx RACT for existing combustion sources.56

No contingency measure shall be implemented without providing the opportunity for full public participation during which the relative costs and benefits of individual measures, at the time they are under consideration, can be fully evaluated.

Requirement 4 of 4

A list of VOC and NO

x sources potentially subject to future additional control requirement s.

Demonstration The following is a list of VOC and NO

x sources potentially subject to

future controls.

NO

x RACT

 EGUs

 asphalt b atching plants

 industrial/commercial and institutional boilers

 process heaters

 internal combustion engines

 combustion turbines

 other sources greater than 100 tons per year

VOC RACT

 architectural and industrial maintenance coatings

 automobile refinishing s hops

 cold cleaner degreasers

 synthetic organic compound manufacturing

 organic compound batch processes

 wood manufacturing

 industrial wastewater

 aerospace in dustry

 bakeries

 plastic parts coating

 volatile organic liquid storage

 industrial solvent cleaning

 of fset lithography

 industrial surface coating

 other sources greater than 50 tons per year57



### CHAPTER SEVEN

MODELING ANALYSIS

Summary of Modeling Results for National Emission Control Strategies in

Final Rulemakings

Although U.S. EPA’s Redesignation Guidance does not require modeling for

ozone nonattainment areas seeking redesignation, extensive modeling has been performed covering the Cincinnati, OH

- KY

- IN, area to determine the effect of national emission control strategies on ozone levels. This area

include s Butler, Clermont, Clinton, Hamilton, and Warren Counties in Ohio

. These modeling analyses determined that this area was significantly impacted by ozone and ozone precursor transport and regional NOx reductions will help

the area attain the 2008 eight

- hou r ozone standard of 75 ppb in this area.

U.S. EPA Modeling Analysis for Interstate Transport “Good Neighbor”

Provision

U.S. EPA conducted modeling for the Interstate Transport “Good Neighbor”

Provision. This analysis was performed in 2014 and included i n the “Air Quality Modeling Technical Support Document for the 2008 Ozone NAAQS Transport Assessment” to assist states in developing “Good Neighbor SIPs,” as required by the CAA to address interstate transport of air pollution that affects

downwind states' ability to attain and maintain the 2008 eight

- hour ozone

standard

. Some of the major federal emission strategies included in the modeling are: National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Reciprocating Internal Combustion Engine s (RICE) and cement manufacturing plants, the Boiler Maximum Achievable Control Technology (MACT) rule, the Energy Independence and Security Act (EISA)

renewable fuel standard mandate, New Source Performance Standards (NSPS) for VOC controls, the Mobile So urce Air Toxics rule, Tier III Emission Standards for Vehicles and Gasoline Sulfur Standards, Emission Standards for Locomotives and Marine Compression

- Ignition Engines, and the Nonroad Spark

- Ignition Engines and Recreational Engine Standards.

This modeli ng was conducted to identify monitoring sites that may have difficulty attaining the 2008 eight

- hour o zone standard in 2018 and identify states that were contributing to attainment issues at a given monitoring site. The air quality model used for this rule making was the Comprehensive Air Quality Model with Extensions (CAMx) version 6.10. The modeling domain consisted of a 12 kilometer (km) x 12 km coarse grid covering the continental

United States and portions of Canada and Mexico and 25 vertical layers fro m the surface up through the troposphere to a height of 50 millibars of pressure. Base year 2011 emissions were modeled. Meteorology from 2011 was created using the Weather Research Forecasting (WRF) Model version 3.4 and was used for the base case and pro jected year modeling runs. More detailed58

information on the CAMx input file and additional data used for the photochemical modeling can be found in U.S. EPA’s “Air Quality Modeling Technical Support Document for the 2008 Ozone NAAQS Transport Assessment,” dated January 2015.

Table 38 shows the results of U.S. EPA’s “Good Neighbor” Provision modeling

for ozone impacts at the ozone monitors in the Cincinnati area. The monitor identification number, county, and state locations are listed, as well as the

2009

– 2013 eight

- hour ozone base period average design values that were used to calculate 2018 projected average design values. Note that the 2009

– 2013 average design values were calculated by averaging the three 3

- year design values from 2009

– 2011, 2010

– 2012, and 2011

– 2013.

Model results are used in a relative rather than absolute sense. Relative use of

the model results calculates the fractional change in maximum concentrations

based on two different emission scenarios, 2011 NEI emissions and 2018

pro jected emissions for this exercise. This fractional change, also known as a relative response factor (RRF), can be applied to each monitor’s average base period design value to determine ozone impacts. This approach differs from using the absolute or actua l modeled result, which may show under

- or over

predictions with the actual monitored values. The 2009

– 2013 average design values were multiplied by the corresponding RRF to determine all 2018 projected average design values.

T able 3 8

- Comparison of Cin cinnati Area Average Design Values with

U.S. EPA “Good Neighbor” Provision Modeling Results ( ppm )

Due to the differences in the base period 2009

– 2013 average design values

and the most current average design values for all of the Cincinnati area ozon e monitors, a comparison of these two values, as well as the 2018 projected average design values taken from the “Good Neighbor” Provision was made,59

and are presented in Table 39

. The current average design values were calculated by averaging the three 3

- y ear design values from 2010

– 2012,

2011

– 2013, and 2012

– 2014.

Comparison of the 2009

– 2013 average design values with the most current

3

- year average design value for all ozone monitors in the Cincinnati area show the most current average design valu es are below the average eight

- hour ozone design values for 2009

– 2013, with the exception of the Campbell County, Kentucky, monitor that had an increase of 0.0003 ppm.

Based on the 2009

– 2013 average design values, the 2018 projected average design val ues modeled well below the 2008 eight

- hour ozone standard of 75 ppb . With the exception of the Campbell County, Kentucky monitor, if the modeling was conducted with the 2010

– 2014 average design values, the 2018 projected average design values would be lo wer than the current results,

further re

- enforcing maintenance of the standard. For the highest monitor in the area (Hamilton County ) , the 2018 projected average design value is

0.0 732 ppm, well below the level of the 2008 eight

- hour ozone standard that

de monstrates attainment (0.0757 ppm) . Even if the modeling was performed using the slightly higher 2010

– 2014 a verage design value, it is expected that the 2018 projected average design value would still be well below the standard

for the Hamilton County mo nitor.

T able 39

- Comparison of Cincinnati Area Current Design Values with

U.S. EPA “Good Neighbor” Design Values ( ppm )60

LADCO Modeling for Eight

- Hour Ozone Standard

The LADCO performed photochemical modeling for ozone, which used the

most recent e missions inventories and model updates. This modeling was performed to support attainment demonstrations for the five

- state LADCO region. The photochemical model used by LADCO and Indiana for the eight

hour ozone standard analysis is CAMx version 6.11, dev eloped by Environ. This model has been accepted by U.S. EPA as an approved air quality model for regulatory analysis and attainment demonstrations. Requirements of 40 CFR 51.112, as well as the “Guidance on the Use of Models and Other Analyses in Attainmen t Demonstrations for the 8

- hour Ozone NAAQS” (EPA

454/R

- 05

- 002, Oct. 2005), are satisfied with the use of CAMx for attainment demonstrations. Meteorology from 2011, as well as 2011 base year emissions (based on legally enforceable emission controls require d by consent decrees, state rules, or permit), was used to conduct this modeling. The base period

average design values for attainment purposes were calculated from the periods 2009

– 2011, 2010

– 2012, and 2011

– 2013. The projected year

modeled was 2018.

Table 4 0 shows that modeled ozone concentrations in the Cincinnati area for

2018 will be below the eight

- hour ozone standard of 75 ppb . As shown in

Table 39 above, the current 2010

– 2014 average design values decreased

from the 2009

– 2013 average desig n values, with the exception of the Campbell County, Kentucky monitor, which increased by 0.0003 ppm. At the

other monitors, where the design values have decreased, the projected average design values would be lower than the LADCO modeling results using

th e latest average design values. For the Campbell County, Kentucky monitor, the projected average design value was well below the 2008 eight

- hour ozone

standard at 0.0719 ppm. As with U.S. EPA’s modeling, even if the LADCO modeling was performed using the s lightly higher 2010

– 2014 average design value, it is expected that the 2018 projected average design value would still

be well below the standard for the Campbell County monitor.61

Table 40

- LADCO’s Modeling Results for the Cincinnati Area ( ppm )

Summ ary of Existing Modeling Result s

U.S. EPA and LADCO modeling shows that national emission control measures will bring the Cincinnati ar ea into attainment of the 2008 eight

- hour ozone NAAQS by 2018, if not earlier. Rulemakings to be implemented in the

next several years will provide assurance that air quality will continue to meet the standard into the future. U.S. EPA’s modeling support for the Interstate Transport “Good Neighbor” Provision show future year design values for the

Cincinnati area will attain the ozone standard with 2018 projected average design values below the 2008 eight

- hour ozone standard of 75 ppb . In addition, LADCO’s modeling results continue to show 2018 projected average design values below the eight

- hour ozone standard . U.S. EPA and LADCO modeling demonstrates that the Cincinnati, OH

- KY

- IN, ozone nonattainment

area will attain the 2008 eight

- hour ozone standard. Future national and local emission control strategies will ensure that the area’s attainment will be

maintained with an incr easing margin of safety over time.62



### CHAPTER EIGHT

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for publi c comment concerning the draft redesignation petition and maintenance p lan in

the widely distributed county p ub lications

.

The p ublic hearing to receive comments on the redesignation re quest was held on March 3 , 201 6 at 50 William Howard Taft Road, Cincinnati, Ohio

45219 . T he public comment peri od close d on March 3 , 201 6

. No testimony was provided at the publi c hearing and two c omments were received during the public comment period. Appendix E includes a copy of the public notice

, transcript from the public hearing and response to comments received during the comment period

.63



### CHAPTER NINE

CONCLUSIONS

The Ci ncinnati

, OH

- KY

- IN ozone nonattainment area has attained the 2008
NAAQS for ozone and complied with the applicable provisions of the 1990

Amendments to the CAA regarding redesignations of ozone nonattainment

areas. Documentation to that effect is containe d herein. Ohio EPA has

prepa red a redesignation request and maintenance p lan that meet the requirement s of Section 110 (a)(1) of the 1990 CAA

.

Based on this presentation, the Cincinnati

, OH

- KY

- IN ozone nonattainment area meets the requirements for rede signation under the CAA and U.S. EPA guidance. Ohio has performed an analysis that shows the air quality improvements are due to permanent and enforceable measures. Furthermore, because this area is subject to significant transport of pollutants, signifi cant regional NO

x reductions will ensure continued compliance (maintenance) with the standard with an increasing margin of safety.

The State of O hio hereby requests that the Cincinnati

, OH

- KY

- IN ozone nonattainment area be redesignated to attainment simul taneously with U.S.

EPA approval of the maintenance p lan provisions contained herein. In addition, the State of Ohio requests that this maintenance plan satisfy the requirements of CAA Section 175A (b), for subsequent plan revisions required

for areas red esignated for the eight

- hour ozone standard

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